Article 2 Definitions

1.

a)

the terms ‘a Contracting State’ and ‘the other Contracting State’ mean the Kingdom of Bahrain or the Kingdom of the Netherlands (the Netherlands), as the context requires; the term ‘Contracting States’ means the Kingdom of Bahrain and the Kingdom of the Netherlands (the Netherlands);

b)

as regards the Kingdom of the Netherlands, the present Agreement shall apply to that part of the Kingdom which is situated in Europe only;

c)

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

d)

the term ‘resident of a Contracting State’ means:

(i)

in the case of the Netherlands: any person, who under Dutch law, is liable to tax by reason of his domicile, residence, place of effective management or any other criterion of a similar nature;

(ii)

in the case of Bahrain: any person, who under Bahrain law is domiciled or has their place of management in Bahrain;

e)

the term ‘air transport enterprise of a Contracting State’ means an enterprise involved in international air traffic and carried on or managed by a person who is a resident of a Contracting State or is a designated airline according to the Air Services Agreement between the Contracting States.

f)

the term ‘international traffic’ means any transport by an aircraft, owned, leased or chartered, operated by an air transport enterprise of a Contracting State, except when the aircraft is operated solely between places in the other Contracting State;

g)

‘tax’ and ‘taxes’ mean all taxes imposed on total or on elements of income or on gains from alienation of movable or immovable property or capital on air transport enterprises or all taxes on the total amounts of wages or salaries levied on their employees;

h)

the term ‘competent authority’ means:

(i)

in the case of Bahrain, the Minister of Finance or his authorised representative;

(ii)

in the case of the Netherlands, the Minister of Finance or his authorised representative.

2.