Tax treaty definitions delimit territorial scope, resident persons, enterprises, nationals and competent authorities under the treaty. The treaty defines key terms for its operation: each State's territory includes territorial seas, airspace and maritime zones; 'person', 'company', 'enterprise' and 'national' cover individuals, corporate and other taxable entities under domestic law; 'international traffic' excludes wholly domestic carriage in the other State; and 'competent authority' designates each State's responsible tax ministry. A residual provision provides that undefined terms bear the meaning given by the domestic law of the Contracting State applying the Convention, unless context dictates otherwise.
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 delimit territorial scope, resident persons, enterprises, nationals and competent authorities under the treaty.
The treaty defines key terms for its operation: each State's territory includes territorial seas, airspace and maritime zones; "person", "company", "enterprise" and "national" cover individuals, corporate and other taxable entities under domestic law; "international traffic" excludes wholly domestic carriage in the other State; and "competent authority" designates each State's responsible tax ministry. A residual provision provides that undefined terms bear the meaning given by the domestic law of the Contracting State applying the Convention, unless context dictates otherwise.
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