For example, in Thiel, the construction issues concerned the interpretation of the terms “profits of an enterprise of an enterprise of an enterprise of one of the Contracting States” in Article 7 of the Double Taxation Convention between Australia and Switzerland,[28] where the terms “enterprise” and “profits” had no particular meaning or was established under Australian income tax law. Tax treaties may also use terms that make no sense under national law, such as. B the concept of “economic property”, which is not recognised by the national laws of many countries. Another consideration is that a bilateral agreement is often written in the language of each of the States Parties, but in Australia only the English text is adopted under Australian law. .
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