DT6502 - DT: Egypt: double taxation agreement, Article 3: General definitions

1. In this Convention, unless the context otherwise requires:

1. 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 subsoil and their natural resources may be exercised:
2.  

(i) the term `Egypt` means the Arab Republic of Egypt; and
(ii) when used in a geographical sense the term `Egypt` includes:

1. the territorial sea thereof; and
2. the sea bed and subsoil of the submarine areas adjacent to the coast thereof, but beyond the territorial sea, over which Egypt exercises sovereign rights, in accordance with international law, for the purpose of exploration and exploitation of the natural resources of such area, but only to the extent that the person, property, or activity to which this Convention is being applied is connected with such exploration or exploitation;
3. the term `national` means:

(i) in relation to the United Kingdom, any citizen of the United Kingdom and Colonies who derives his status as such from his connection with 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 Egypt, any individual possessing the nationality of the Arab Republic of Egypt and any legal person, partnership and association deriving its status as such from the law in force in Egypt;

4. the term `tax` means United Kingdom tax or Egyptian tax, as the context requires;
5. the terms `a Contracting State` and `the other Contracting State` mean the United Kingdom or Egypt, as the context requires;
6. the term `person` comprises an individual, a company and any other body of persons;
7. the term `company` means any body corporate or any entity which is treated as a body corporate for tax purposes;
8. 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;
9. 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 Egypt, the Minister of Finance or his authorised representative;
10. the term `international traffic` includes traffic between places in one country in the course of a voyage which extends over more than one country.

2. 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.