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 ... Summary
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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