Article 3(2) and the Search for Meaning: How to Interpret Undefined Terms in Double Tax Treaties (Part 1)

Summary: Double tax treaties use many undefined terms. For example, "fixed place of business" (used in Article 5) and "beneficial owner" (used in Articles 10, 11 and 12) are very important, but generally undefined, terms in treaties. What approach should you follow to determine the meaning of undefined terms in treaties? Understand the approach to follow in order to identify the meaning of undefined terms in double tax treaties. (Live presentation was aired on 18 Jun 2013)