Definitions in double tax agreements determine scope of key terms and governing tax treatment between contracting states. The Convention defines key terms that determine its application: person (individuals, companies, other bodies), company (bodies corporate or fiscally treated as such), enterprise and residence-linked enterprise concepts, international traffic, competent authority, national, and business (including professional services). It recognises a recognised pension fund as an entity primarily for retirement benefits or investment for such funds, and provides that undefined terms are to be given meaning from the domestic tax law of the applying Contracting State unless context or mutual agreement under Article 25 dictates otherwise.
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.
Definitions in double tax agreements determine scope of key terms and governing tax treatment between contracting states.
The Convention defines key terms that determine its application: person (individuals, companies, other bodies), company (bodies corporate or fiscally treated as such), enterprise and residence-linked enterprise concepts, international traffic, competent authority, national, and business (including professional services). It recognises a recognised pension fund as an entity primarily for retirement benefits or investment for such funds, and provides that undefined terms are to be given meaning from the domestic tax law of the applying Contracting State unless context or mutual agreement under Article 25 dictates otherwise.
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