Tax treaty definitions set the governing meanings for parties and preserve domestic law meanings for undefined terms. Article 3 sets the Convention's definitional regime: it defines principal terms such as the Contracting States, 'tax', 'person', 'company', 'enterprise of a Contracting State' and the Competent Authority for each State. It further provides that any term not defined in the Convention shall, unless the context otherwise requires, bear the meaning it has under the domestic laws of the State applying the Convention in relation to the taxes covered.
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 set the governing meanings for parties and preserve domestic law meanings for undefined terms.
Article 3 sets the Convention's definitional regime: it defines principal terms such as the Contracting States, "tax", "person", "company", "enterprise of a Contracting State" and the Competent Authority for each State. It further provides that any term not defined in the Convention shall, unless the context otherwise requires, bear the meaning it has under the domestic laws of the State applying the Convention in relation to the taxes covered.
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