DT6720.3 - DT: Estonia: double taxation agreement, Article 3: General definitions

1. For the purposes of this Convention, unless the context otherwise requires:
   
   

1. the term 'Estonia' means the Republic of Estonia and, when used in the geographical sense, means the territory of Estonia and any other area adjacent to the territorial waters of Estonia within which, under the laws of Estonia and in accordance with international law, the rights of Estonia may be exercised with respect to the seabed and its sub-soil and their natural resources;
   
   
2. 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 seabed and sub-soil and their natural resources may be exercised;
   
   
3. the term 'national' means:
   
   

(i) in relation to Estonia, all individuals possessing the nationality of the Republic of Estonia; and any legal person, partnership or association deriving its status as such from the laws in force in the Republic of Estonia;
(ii) 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;

4. the terms 'a Contracting State' and 'the other Contracting State' mean the United Kingdom or Estonia, as the context requires;
   
   
5. the term 'person' includes an individual, a company and any other body of persons, but subject to paragraph 2 of this Article does not include a partnership;
   
   
6. the term 'company' means any body corporate or any entity which is treated as a body corporate for tax purposes;
   
   
7. 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;
   
   
8. the term 'international traffic' means any transport by a ship or aircraft operated by an enterprise of a Contracting State, except when the ship or aircraft is operated solely between places in the other Contracting State;
   
   
9. the term 'competent authority' means:
   
   

(i) in the case of Estonia, the Minister of Finance or his authorised representative; and
(ii) in the case of the United Kingdom, the Commissioners of Inland Revenue or their authorised representative.

2. A partnership deriving its status from Estonian law which is treated as a taxable unit under the law of Estonia shall be treated as a person for the purposes of this Convention.
   
   
3. As regards the application of this Convention by a Contracting State any term not defined therein shall, unless the context otherwise requires, have the meaning which it has under the laws of that Contracting State concerning the taxes to which the Convention applies.