Tax treaty definitions govern residence, enterprise, competent authority roles and mechanisms to resolve conflicting tax terms. Article 3 defines territorial scope and key treaty terms-person, company, enterprise, international traffic, competent authority, national, fiscal year and tax-noting tax excludes penalties. It directs that undefined terms adopt the applying State's domestic meaning, permits competent authorities to agree a common meaning where meanings differ or are indeterminate, and allows them to agree on source attribution in particular cases to eliminate double taxation.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Tax treaty definitions govern residence, enterprise, competent authority roles and mechanisms to resolve conflicting tax terms.
Article 3 defines territorial scope and key treaty terms-person, company, enterprise, international traffic, competent authority, national, fiscal year and tax-noting tax excludes penalties. It directs that undefined terms adopt the applying State's domestic meaning, permits competent authorities to agree a common meaning where meanings differ or are indeterminate, and allows them to agree on source attribution in particular cases to eliminate double taxation.
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