Tax treaty definitions clarify scope of tax, person, company, enterprise, competent authority and international traffic. General definitions set core treaty terms: India and Philippines denote their national territories (including maritime zones for India); 'Contracting State' references either Party; 'tax' excludes penalties and default amounts; 'person', 'company', and 'enterprise' are defined by resident status and domestic taxation treatment; the Convention identifies each Party's 'competent authority' and defines 'national' and 'international traffic'. Any term not defined in the Convention shall, unless context requires otherwise, have the meaning it holds under the applying Contracting State's domestic tax law.
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Provisions expressly mentioned in the judgment/order text.
Tax treaty definitions clarify scope of tax, person, company, enterprise, competent authority and international traffic.
General definitions set core treaty terms: India and Philippines denote their national territories (including maritime zones for India); "Contracting State" references either Party; "tax" excludes penalties and default amounts; "person", "company", and "enterprise" are defined by resident status and domestic taxation treatment; the Convention identifies each Party's "competent authority" and defines "national" and "international traffic". Any term not defined in the Convention shall, unless context requires otherwise, have the meaning it holds under the applying Contracting State's domestic tax law.
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