Definition of tax clarifies scope and excludes penalties, shaping application of the Contracting States' tax treaty. Article 3 sets core definitions for the treaty: territorial scope of each Contracting State (including adjacent waters, air-space and specified maritime zones), the meaning of 'tax' excluding penalties and payments for defaults, definitions of 'person', 'company' and 'enterprise' as determined by domestic taxation law, identification of competent authorities for each State, and the definition of 'national'. It also provides that any term not defined in the Agreement shall, unless context otherwise requires, have the meaning given by the domestic tax law of the Contracting State applying the provision.
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.
Definition of tax clarifies scope and excludes penalties, shaping application of the Contracting States' tax treaty.
Article 3 sets core definitions for the treaty: territorial scope of each Contracting State (including adjacent waters, air-space and specified maritime zones), the meaning of "tax" excluding penalties and payments for defaults, definitions of "person", "company" and "enterprise" as determined by domestic taxation law, identification of competent authorities for each State, and the definition of "national". It also provides that any term not defined in the Agreement shall, unless context otherwise requires, have the meaning given by the domestic tax law of the Contracting State applying the provision.
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