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 ... Summary
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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