Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.
ARTICLE 1
General Definitions
(1) For the purposes of this Agreement, unless the context otherwise requires:
- (a) the term "Member State" means one of the States as per Schedule I;
- (b) the term "person" includes an individual, a company, a body of persons and any other entity which is treated as a taxable unit under the taxation laws in force in the respective Member States;
- (c) the term "tax" means, tax(es) covered as per Schedule II, as the context requires;
- (d) the term "Competent Authority" means Competent Authority as per Schedule III;
- (e) the term "national" means any individual possessing the nationality of a Member State; and
- (f) the term "fiscal year" means the year as defined in Schedule IV.
(2) As regards the application of the Agreement at any time by a Member 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 Member State for the purposes of the taxes to which the Agreement applies and any meaning under the applicable tax laws of that Member State prevailing over a meaning given to the term under other laws of that Member State.