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Tax treaty definitions clarify residence, enterprise scope, competent authority, fiscal year and interpretation rules under domestic tax law. The Convention supplies core definitions governing its application between Hungary and India: territorial scope; who counts as a Contracting State, person, company, enterprise and national; the concept of international traffic; each State's competent authority; fiscal year definitions; and a limiting definition of tax excluding penalties. It mandates that undefined terms be interpreted according to the applying State's domestic tax law at the relevant time, with tax-law meanings prevailing over other domestic-law meanings.
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Provisions expressly mentioned in the judgment/order text.
Tax treaty definitions clarify residence, enterprise scope, competent authority, fiscal year and interpretation rules under domestic tax law.
The Convention supplies core definitions governing its application between Hungary and India: territorial scope; who counts as a Contracting State, person, company, enterprise and national; the concept of international traffic; each State's competent authority; fiscal year definitions; and a limiting definition of tax excluding penalties. It mandates that undefined terms be interpreted according to the applying State's domestic tax law at the relevant time, with tax-law meanings prevailing over other domestic-law meanings.
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