Einde inhoudsopgave
Convention between the Government of the Kingdom of the Netherlands and the Government of the Kingdom of Saudi Arabia for the avoidance of double taxation and the prevention of tax evasion with respect to taxes on income
Article 3 General definitions
Geldend
Geldend vanaf 01-12-2010
- Bronpublicatie:
13-10-2008, Trb. 2008, 214 (uitgifte: 17-12-2008, kamerstukken/regelingnummer: -)
- Inwerkingtreding
01-12-2010
- Bronpublicatie inwerkingtreding:
23-12-2010, Trb. 2010, 329 (uitgifte: 23-12-2010, kamerstukken/regelingnummer: -)
- Vakgebied(en)
Internationaal belastingrecht (V)
Internationaal belastingrecht / Belastingverdragen
1.
For the purposes of this Convention, unless the context otherwise requires:
- a)
the terms ‘a Contracting State’ and ‘the other Contracting State’ mean the Kingdom of Saudi Arabia or the Kingdom of the Netherlands, as the context requires;
- b)
the term ‘Kingdom of Saudi Arabia’ means the territory of the Kingdom of Saudi Arabia which also includes the area outside the territorial waters, where the Kingdom of Saudi Arabia exercises its sovereign and jurisdictional rights in their waters, sea bed, sub-soil and natural resources by virtue of its law and international law;
- c)
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;
- d)
the term ‘person’ includes any natural person, any company and any other body of persons, including inter alia bodies politic, (the State, its political or administrative sub-division or local authorities), partnerships, trusts and foundations;
- e)
the term ‘company’ means any juridical person or any entity which is treated as a juridical person 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 ‘national’ means:
- (i)
any individual possessing the nationality of a Contracting State;
- (ii)
any legal person, partnership and association deriving its status as such from the laws in force in a Contracting State;
- h)
the term ‘international traffic’ means any transport by a ship or aircraft operated by an enterprise which 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;
- i)
the term ‘competent authority’ means:
- (i)
in the case of the Kingdom of Saudi Arabia, the Ministry of Finance represented by the Minister of Finance or his authorized representative;
- (ii)
in the case of the Netherlands, the Minister of Finance or his authorized representative.
2.
As regards the application of this Convention at any time by a Contracting State, any term not defined therein shall, unless the context otherwise requires, have the meaning that it has at that time under the law of that State for the purposes of the taxes to which this Convention applies, any meaning under the applicable tax laws of that State prevailing over a meaning given to the term under other laws of that State.