General definitions in a tax treaty clarify residency, taxable persons, competent authority roles and fiscal-year application. Article 3 sets out the Convention's key definitions: the territorial references for the Contracting States; the meanings of person, company, enterprise of a Contracting State, international traffic, national, fiscal year and tax; identification of the competent authority in each State; exclusion of penalties from the definition of tax; and that undefined terms are to be interpreted by the domestic law of the applying Contracting State.
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.
General definitions in a tax treaty clarify residency, taxable persons, competent authority roles and fiscal-year application.
Article 3 sets out the Convention's key definitions: the territorial references for the Contracting States; the meanings of person, company, enterprise of a Contracting State, international traffic, national, fiscal year and tax; identification of the competent authority in each State; exclusion of penalties from the definition of tax; and that undefined terms are to be interpreted by the domestic law of the applying Contracting State.
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