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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.


General Definitions

(1) In this Agreement, unless the context otherwise requires:

  • (a) the term "India" means the territory of India and includes the territorial sea and airspace above it, as well as any other maritime zone in which India has sovereign rights, other rights and jurisdictions, according to the Indian law and in accordance with international law/U.N. Convention on the Law of the Sea;
  • (b) the term "Czechoslovakia" means the Czechoslovak Socialist Republic;
  • (c) the terms "a Contracting State" and "the other Contracting State" mean India or Czechoslovakia, as the context requires;
  • (d) the term "tax" means Indian tax or Czechoslovak tax, as the context requires;
  • (e) the term "person" shall have the meaning assigned to it in the taxation laws in force in the respective Contracting States;
  • (f) the term "company" means any body corporate or any entity which is treated as a company under the taxation laws of the respective Contracting States;
  • (g) the terms "enterprise of a Contracting State" and "enterprise of the other Contracting State" mean, respectively, an enterprise carried on by a resident of a Contracting State and an enterprise carried on by a resident of the other Contracting State;
  • (h) the terms "competent authority" means in the case of India, the Central Government in the Ministry of Finance (Department of Revenue); and in the case of Czechoslovakia, the Minister of Finance of the Czechoslovak Socialist Republic or his duly authorised representative.

(2) In the application of the provisions of this Agreement by one of the Contracting States, any term not defined herein shall, unless the context otherwise requires, have the meaning which it has under the laws in force in that Contracting State relating to the taxes which are the subject of this Agreement.