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




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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? In this Part 2 webcast, we will continue the discussion of this topic which we commenced in our Part 1 webcast (18 June 2013). Understand the approach to follow in order to identify the meaning of undefined terms in double tax treaties.(Live presentation was aired on 1 Aug 2013)