Definitions of 'person' and 'enterprise' clarify residency-based tax scope under the India-Thailand double tax agreement. Article 3 defines key terms for the India-Thailand tax convention: territorial scope of India and Thailand including maritime zones; 'a Contracting State' and 'the other Contracting State'; 'tax' as Indian or Thai tax; 'person' and 'company' to include individuals, bodies corporate and other taxable entities; 'enterprise' defined by residence; 'competent authority' as the designated fiscal authorities of each State; 'national' including natural and legal persons; 'international traffic' limited to transport by an enterprise of a Contracting State. Article 3(2) provides that undefined terms take their meaning from the domestic tax law of the applying State.
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Provisions expressly mentioned in the judgment/order text.
Definitions of 'person' and 'enterprise' clarify residency-based tax scope under the India-Thailand double tax agreement.
Article 3 defines key terms for the India-Thailand tax convention: territorial scope of India and Thailand including maritime zones; "a Contracting State" and "the other Contracting State"; "tax" as Indian or Thai tax; "person" and "company" to include individuals, bodies corporate and other taxable entities; "enterprise" defined by residence; "competent authority" as the designated fiscal authorities of each State; "national" including natural and legal persons; "international traffic" limited to transport by an enterprise of a Contracting State. Article 3(2) provides that undefined terms take their meaning from the domestic tax law of the applying State.
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