Tax treaty definitions clarify residency, taxable persons, enterprises, and competent authority roles affecting allocation of taxing rights. Article 3 provides core treaty definitions including territorial scope, definitions of person, company, enterprise of a Contracting State, and international traffic; identifies each State's competent authority; and defines national, fiscal year, and tax while excluding penalties. It further directs that any term not defined in the Agreement will, unless the context otherwise requires, have the meaning assigned by the domestic law of the Contracting State applying the Agreement.
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 clarify residency, taxable persons, enterprises, and competent authority roles affecting allocation of taxing rights.
Article 3 provides core treaty definitions including territorial scope, definitions of person, company, enterprise of a Contracting State, and international traffic; identifies each State's competent authority; and defines national, fiscal year, and tax while excluding penalties. It further directs that any term not defined in the Agreement will, unless the context otherwise requires, have the meaning assigned by the domestic law of the Contracting State applying the Agreement.
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