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SCHEDULECONVENTION

BETWEEN THE GOVERNMENT OF THE UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND AND THE GOVERNMENT OF THE REPUBLIC OF ICELAND FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME AND CAPITAL GAINS

ARTICLE 3General definitions

(1) In this Convention, unless the context otherwise requires:

(a)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;

(b)the term “Iceland” means the Republic of Iceland, including any area adjacent to the territorial sea of Iceland within which under the laws of Iceland and in accordance with international law, Iceland has soverign rights for the purpose of exploring and exploiting the natural resouces of the sea bed and sub-soil;

(c)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 Iceland, any individual possessing Icelandic nationality and any legal person, partnership, association or other entity deriving its status as such from the law in force in Iceland;

(d)the term “tax” means United Kingdom tax or Icelandic tax, as the context requires;

(e)the terms “a Contracting State” and “the other Contracting State” mean the United Kingdom or Iceland as the context requires;

(f)the term “person” comprises an individual, a company and any other body of persons but does not include partnerships which are not treated as bodies corporate for tax purposes in either Contracting State;

(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” means 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” means any transport by a ship or aircraft operated by an enterprise which 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;

(j)the term “political subdivision” in relation to the United Kingdom, includes Northern Ireland;

(k)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 Iceland, the Minister of Finance or his authorised representative.

(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 law of that Contracting State concerning the taxes to which the Convention applies.