Definitions of treaty terms govern scope, connected persons, pension funds, and identification of special tax regimes under the model. Article 3 defines key treaty terms: 'person,' 'company,' 'enterprise,' 'business,' 'international traffic,' 'competent authority,' 'United States,' 'national,' pension fund, and the test for connected persons. It requires undefined terms to take their meaning from the domestic law of the applying Contracting State unless the competent authorities agree otherwise. It sets a comprehensive, conditional definition of special tax regime, listing objective features, exclusions and a diplomatic identification procedure before a regime is treated as special.
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 of treaty terms govern scope, connected persons, pension funds, and identification of special tax regimes under the model.
Article 3 defines key treaty terms: "person," "company," "enterprise," "business," "international traffic," "competent authority," "United States," "national," pension fund, and the test for connected persons. It requires undefined terms to take their meaning from the domestic law of the applying Contracting State unless the competent authorities agree otherwise. It sets a comprehensive, conditional definition of special tax regime, listing objective features, exclusions and a diplomatic identification procedure before a regime is treated as special.
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