Residence definition determines tax liability and guides treaty application between Contracting States under designated competent authorities. The Convention defines key terms: Contracting State, person, Company, enterprise of a Contracting State, and competent authority; it defines resident of a Contracting State by domestic tests of liability to taxation and provides that undefined terms take their meaning from the domestic tax law of the relevant Contracting State unless the context otherwise requires.
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.
Residence definition determines tax liability and guides treaty application between Contracting States under designated competent authorities.
The Convention defines key terms: Contracting State, person, Company, enterprise of a Contracting State, and competent authority; it defines resident of a Contracting State by domestic tests of liability to taxation and provides that undefined terms take their meaning from the domestic tax law of the relevant Contracting State unless the context otherwise requires.
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