Transfer pricing

Article 3 - General Definitions


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Article 3


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

a) the term "person" includes an individual, a company and any other body of
b) the term "company" means any body corporate or any entity that is treated as a
body corporate for tax purposes;
c) the term "enterprise" applies to the carrying on of any business;
d) 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;
e) the term "international traffic" means any transport by a ship or aircraft operated
by an enterprise that has its place of effective management in a Contracting State,
except when the ship or aircraft is operated solely between places in the other
Contracting State;
f) the term "competent authority" means:

(i) (in State A): ................................
(ii) (in State B): ................................

g) the term "national", in relation to a Contracting State, means:

(i) any individual possessing the nationality or citizenship of that Contracting
State; and
(ii) any legal person, partnership or association deriving its status as such from
the laws in force in that Contracting State;

h) the term "business" includes the performance of professional services and of other
activities of an independent character.

2. As regards the application of the Convention at any time by a Contracting State, any
term not defined therein shall, unless the context otherwise requires, have the meaning that
it has at that time under the law of that State for the purposes of the taxes to which the
Convention applies, any meaning under the applicable tax laws of that State prevailing over
a meaning given to the term under other laws of that State. 



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