Definitions of territorial scope and residence determine the Convention's taxing boundaries and treaty application. Article 3 defines the Convention's key terms: territorial scope by specifying what constitutes each Contracting State including maritime zones; tax as the relevant State tax excluding penalties; and categories of taxable persons and entities by defining 'person,' 'company,' 'enterprise,' and 'national.' It limits 'international traffic' to qualifying transport operations and names each State's competent authority. Any term not defined takes its meaning from the domestic tax law of the applying State.
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 territorial scope and residence determine the Convention's taxing boundaries and treaty application.
Article 3 defines the Convention's key terms: territorial scope by specifying what constitutes each Contracting State including maritime zones; tax as the relevant State tax excluding penalties; and categories of taxable persons and entities by defining "person," "company," "enterprise," and "national." It limits "international traffic" to qualifying transport operations and names each State's competent authority. Any term not defined takes its meaning from the domestic tax law of the applying State.
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