Article 3 General definitions

1.

a)

the term ‘person’ includes an individual, a company and any other body of persons;

b)

the term ‘company’ means any body corporate or any entity that is treated as a body corporate for tax purposes;

c)

the term ‘enterprise’ applies to the carrying on of any business;

d)

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;

e)

the term ‘international traffic’ means any transport by a ship or aircraft except when the ship or aircraft is operated solely between places in a Contracting State and the enterprise that operates the ship or aircraft is not an enterprise of that State;

f)

the term ‘competent authority’ means:

(i)

(in State A): ………

(ii)

(in State B): ………

g)

the term ‘national’, in relation to a Contracting State, means:

(i)

any individual possessing the nationality or citizenship of that Contracting State; and

(ii)

any legal person, partnership or association deriving its status as such from the laws in force in that Contracting State;

h)

the term ‘business’ includes the performance of professional services and of other activities of an independent character.

i)

the term ‘recognised pension fund’ of a State means an entity or arrangement established in that State that is treated as a separate person under the taxation laws of that State and:

(i)

that is established and operated exclusively or almost exclusively to administer or provide retirement benefits and ancillary or incidental benefits to individuals and that is regulated as such by that State or one of its political subdivisions or local authorities; or

(ii)

that is established and operated exclusively or almost exclusively to invest funds for the benefit of entities or arrangements referred to in subdivision (i).

2.