Tax treaty definitions determine scope and application of tax provisions between the contracting states and resident status. Article 3 defines key terms for the bilateral tax treaty, including 'Contracting State,' tax (excluding penalties), 'person,' 'company,' 'enterprise,' 'national,' and 'international traffic.' It designates the respective competent authority in each State as the named ministry or its authorised representative. The Article further provides that terms not defined in the Agreement shall, unless the context requires otherwise, have the meaning they bear 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 determine scope and application of tax provisions between the contracting states and resident status.
Article 3 defines key terms for the bilateral tax treaty, including "Contracting State," tax (excluding penalties), "person," "company," "enterprise," "national," and "international traffic." It designates the respective competent authority in each State as the named ministry or its authorised representative. The Article further provides that terms not defined in the Agreement shall, unless the context requires otherwise, have the meaning they bear under the domestic tax law of the Contracting State applying the Agreement.
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