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
Scope of the Agreement
(1) This Agreement shall apply to persons who are residents of one or both of the Contracting States.
(2)
- (a) This Agreement applies to the territory of each of the Contracting States, including its territorial sea, and to its Exclusive Economic Zone and its Continental Shelf which extends beyond the limits of its territorial sea over which it exercises, under its laws consistent with International Law, sovereign rights for the purpose of exploring and exploiting the natural resources of such areas.
- (b) For the purposes of this Agreement any reference to either of the Contracting States is considered as a reference to the territory of the relevant State, including its territorial sea, its Exclusive Economic Zone and its Continental Shelf which extends beyond the limits of the territorial sea of that State, as mentioned in sub-paragraph (a) above.