General Definitions: residence and taxable person definitions shape application and scope of the tax treaty. The Agreement defines territorial scope, fiscal year distinctions, and limits the meaning of tax to exclude penalties; it designates competent authorities. It classifies person, company, enterprise, international traffic, and national, and provides that any term not defined in the Agreement takes the meaning it has under the domestic law of the applying Contracting State for the covered taxes.
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.
General Definitions: residence and taxable person definitions shape application and scope of the tax treaty.
The Agreement defines territorial scope, fiscal year distinctions, and limits the meaning of tax to exclude penalties; it designates competent authorities. It classifies person, company, enterprise, international traffic, and national, and provides that any term not defined in the Agreement takes the meaning it has under the domestic law of the applying Contracting State for the covered taxes.
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