DT7301 - DT: France: double taxation agreement, Article 2: General definitions
(1) In this Convention:
(a) the term `United Kingdom` means Great Britain and Northern
Ireland, including any area outside the territorial sea of the
United Kingdom which is in accordance with international law, an
area within which the United Kingdom may exercise rights with
respect to the sea bed and sub-soil and their natural resources;
(b) the term `France` means the European and Overseas
Departments (Guadeloupe, Guyane, Martinique and Reunion) of the
French Republic including any area outside the territorial sea of
France which is, in accordance with international law, an area
within which France may exercise rights with respect to the sea bed
and sub-soil and their natural resources;
(c) the terms `a Contracting State` and `the other
Contracting State` mean the United Kingdom or France as the context
requires;
(d) the term `competent authorities` means, in the case of
the United Kingdom, the Commissioners of Inland Revenue or their
authorised representative- in the case of France, the Minister of
Economy and Finance (le Ministre de l'Economie et des Finances) or
his authorised representative- and, in the case of any territory to
which this Convention is extended under Article 29, the competent
authority for the administration in such territory of the taxes to
which this Convention applies;
(e) the term `tax` means United Kingdom tax or French tax as
the context requires;
(f) the term `person` comprises an individual, a company and
any other body of persons;
(g) the term `company` means any body corporate or any
entity which is treated as a body corporate for tax purposes;
(h) 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;
(i) the term `international traffic` includes any voyage of
a ship or aircraft other than a voyage solely between places in the
Contracting State which is not the Contracting State of which a
person deriving the profits of the operation of a ship or aircraft
is a resident.
(2) In the application of the provisions 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.
