The Double Taxation Relief (Taxes on Income) (Russian Federation) Order 1994

Article 3 General definitions

(1) For the purposes of 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 “the Russian Federation” when used in the geographical sense, means its territory, including its territorial waters as well as economic zone and Continental Shelf where this State exercises sovereign rights or rights and jurisdiction in conformity with international law and where its tax laws are effective;

(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;

(ii) in relation to the Russian Federation, any individual possessing its citizenship;

(d) the terms “a Contracting State” and “the other Contracting State” mean the United Kingdom or the Russian Federation, as the context requires;

(e) the term “person” comprises an individual, a company and any other body of persons, but does not include a partnership;

(f) the term “company” means any body corporate or any entity which is treated as a body corporate for tax purposes;

(g) 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;

(h) 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;

(i) 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 the Russian Federation, the Ministry of Finance or its 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 laws of that Contracting State relating to the taxes which are the subject of this Convention.