Tax treaty definitions set territorial scope, persons, enterprises, competent authority and excluded amounts under the Convention. Article 3 fixes the Convention's operative definitions: territorial scope includes land, territorial sea, maritime zones and airspace; undefined terms take their meaning under the applying State's tax law. It defines person, company, enterprise, international traffic (with an exception), national, competent authority for each State, and states that 'tax' means the covered Indian or Namibian taxes but excludes interest, default-related amounts and penalties.
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.
Tax treaty definitions set territorial scope, persons, enterprises, competent authority and excluded amounts under the Convention.
Article 3 fixes the Convention's operative definitions: territorial scope includes land, territorial sea, maritime zones and airspace; undefined terms take their meaning under the applying State's tax law. It defines person, company, enterprise, international traffic (with an exception), national, competent authority for each State, and states that "tax" means the covered Indian or Namibian taxes but excludes interest, default-related amounts and penalties.
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