Einde inhoudsopgave
Agreement between the Government of the Kingdom of the Netherlands and the Government of the State of Qatar for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income
Article 3 General definitions
Geldend
Geldend vanaf 25-12-2009
- Bronpublicatie:
24-04-2008, Trb. 2008, 112 (uitgifte: 27-05-2008, kamerstukken/regelingnummer: -)
- Inwerkingtreding
25-12-2009
- Bronpublicatie inwerkingtreding:
13-01-2010, Trb. 2010, 11 (uitgifte: 13-01-2010, kamerstukken/regelingnummer: -)
- Vakgebied(en)
Internationaal belastingrecht (V)
Internationaal belastingrecht / Belastingverdragen
1.
For the purposes of this Agreement, unless the context otherwise requires:
- a)
the terms ‘a Contracting State’ and ‘the other Contracting State’ mean the Kingdom of the Netherlands (the Netherlands) or the State of Qatar; as the context requires;
- b)
the term ‘the Netherlands’ means the part of the Kingdom of the Netherlands that is situated in Europe, including its territorial sea, and any area beyond the territorial sea within which the Netherlands, in accordance with international law, exercises jurisdiction or sovereign rights;
- c)
the term ‘Qatar’ means the State of Qatar's lands, internal waters, territorial sea including its bed and sub-soil, the air space over them, the exclusive economic zone and the continental shelf, over which the State of Qatar exercises sovereign rights and jurisdiction in accordance with the provisions of international law and Qatar's national laws and regulations;
- d)
the term ‘person’ includes an individual, a company and any other body of persons;
- e)
the term ‘company’ means any body corporate or any entity that is treated as a body corporate for tax purposes;
- f)
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;
- g)
the term ‘international traffic’ means any transport by a ship or aircraft operated by an enterprise that has its place of effective management in a Contracting State, except when the ship or aircraft is operated solely between places in the other Contracting State;
- h)
the term ‘competent authority’ means:
- (i)
in the case of Netherlands the Minister of Finance or his authorised representative; and
- (ii)
in the case of Qatar, the Minister of Finance, or his authorised representative,
- i)
the term ‘national’ in relation to a Contracting State means:
- 1.
any individual possessing the nationality of that Contracting State;
- 2.
any legal person, partnership or association deriving its status as such from the laws in force in that Contracting State;
2.
As regards the application of the Agreement at any time by a Contracting State, any term not defined therein shall, unless the context otherwise requires, have the meaning which it has under the law of that State concerning the taxes to which the Agreement applies.