DT4152 - DT: Bulgaria: double taxation agreement, Article 3: General definitions
- In this Convention, unless the context otherwise requires:
- the term `United Kingdom` means Great Britain and Northern
Ireland, including any area outside the territorial sea of the
United Kingdom which in accordance with international law has been
or may hereafter be designated, under the laws of the United
Kingdom concerning the Continental Shelf, as an area within which
the rights of the United Kingdom with respect to the sea bed and
sub-soil and their natural resources may be exercised;
- the term `Bulgaria` means the People's Republic of Bulgaria and
when used in a geographical sense the territory over which the
People's Republic of Bulgaria exercises its State sovereignty as
well as the Continental Shelf and exclusive economic zone within
which the People's Republic of Bulgaria exercises sovereign rights
in accordance with international law;
- the term `national` means:
(i) in relation to the United Kingdom, any British citizen or any British subject not possessing the citizenship of any other Commonwealth country or territory, provided he has the right of abode in the United Kingdom; and any legal person, partnership, association or other entity deriving its status as such from the law in force in the United Kingdom;
(ii) in relation to Bulgaria, any individual who has under the law of Bulgaria the status of Bulgarian national and any legal person, partnership or other entity deriving its status as such from the law in force in Bulgaria;
- the terms `a Contracting State` and `the other Contracting
State` mean the United Kingdom or Bulgaria as the context requires;
- the term `person` means an individual, and:
(i) in the case of the United Kingdom, a body corporate (including companies or any other entity which is treated as a body corporate for tax purposes) and any other body of persons;
(ii) in the case of Bulgaria, a legal person or any joint venture established in accordance with Bulgarian law, and any other body of persons; but does not include a partnership which is not a legal person.
- 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;
- the term `international traffic` means any transport by a ship,
aircraft or road vehicle operated by an enterprise which has its
place of effective management in a Contracting State, except when
the ship, aircraft or road vehicle is operated solely between
places in the other Contracting State;
- the term `competent authority` means, in the case of the United
Kingdom the Commissioners of Inland Revenue or their authorised
representative, and in the case of Bulgaria the Minister of Finance
or his authorised representative.
- As regards the application of this Convention by a Contracting
State any term not otherwise defined shall, unless the context
otherwise requires, have the meaning which it has under the laws of
that Contracting State relating to the taxes which are the subject
of this Convention.
