Treaty definitions clarify resident, company, enterprise, national, fiscal year and tax scope under the bilateral convention. Definitions determine the Convention's scope by defining resident, company, enterprise, international traffic, competent authority, fiscal year and tax; resident and company include individuals, bodies corporate and other taxable units as defined by domestic law; enterprise of a Contracting State means an enterprise carried on by a resident thereof; international traffic excludes voyages solely between places in the other Contracting State; tax excludes penalties and default amounts. Undefined terms are to be interpreted according to each Contracting State's domestic tax laws unless the Convention's 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.
Treaty definitions clarify resident, company, enterprise, national, fiscal year and tax scope under the bilateral convention.
Definitions determine the Convention's scope by defining resident, company, enterprise, international traffic, competent authority, fiscal year and tax; resident and company include individuals, bodies corporate and other taxable units as defined by domestic law; enterprise of a Contracting State means an enterprise carried on by a resident thereof; international traffic excludes voyages solely between places in the other Contracting State; tax excludes penalties and default amounts. Undefined terms are to be interpreted according to each Contracting State's domestic tax laws unless the Convention's context dictates otherwise.
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