Tax treaty definitions clarify residence, taxable persons, and the domestic-law fallback for undefined terms. Article 3 defines core terms for the India-Malta tax treaty: territorial scope of India and Malta; company as any body corporate or entity treated as such for tax purposes; competent authority as the finance minister or authorised representative; enterprise, national, fiscal year, international traffic, person, and tax (excluding penalties or default amounts). Paragraph 2 provides that undefined terms are to be interpreted by the meaning given under the domestic tax law of the Contracting State applying the Agreement.
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Provisions expressly mentioned in the judgment/order text.
Tax treaty definitions clarify residence, taxable persons, and the domestic-law fallback for undefined terms.
Article 3 defines core terms for the India-Malta tax treaty: territorial scope of India and Malta; company as any body corporate or entity treated as such for tax purposes; competent authority as the finance minister or authorised representative; enterprise, national, fiscal year, international traffic, person, and tax (excluding penalties or default amounts). Paragraph 2 provides that undefined terms are to be interpreted by the meaning given under the domestic tax law of the Contracting State applying the Agreement.
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