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- 1. For the purposes of this Convention, unless the context otherwise requires:
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- a) the term ‘United Kingdom’ means Great Britain and Northern Ireland but, when used in a geographical sense, means the territory and territorial sea of Great Britain and Northern Ireland and the areas beyond that territorial sea over which Great Britain and Northern Ireland exercise sovereign rights or jurisdiction in accordance with their domestic law and international law;
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- b) the term ‘Cyprus’ means the Republic of Cyprus and when used in a geographical sense includes the national territory, the territorial sea thereof as well any area outside the territorial sea, including the contiguous zone, the exclusive economic zone and the continental shelf, which has been or may hereafter be designated, under the laws of Cyprus and in accordance with international law, as an area within which Cyprus may exercise sovereign rights or jurisdiction;
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- c) the terms ‘a Contracting State’ and ‘the other Contracting State’ mean Cyprus or the United Kingdom, as the context requires;
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- d) the term ‘person’ includes an individual, a company and any other body of persons;
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- e) the term ‘company’ means any body corporate or any entity that is treated as a body corporate for tax purposes;
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- f) the term ‘enterprise’ applies to the carrying on of any business;
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- 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;
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- 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;
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- i) the term ‘competent authority’ means:
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- (i) in the United Kingdom, the Commissioners for Her Majesty’s Revenue and Customs or their authorised representative;
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- (ii) in Cyprus the Minister of Finance or the Minister’s authorised representative;
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- j) the term ‘national’ means:
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- (i) in the case of 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 or association deriving its status as such from the laws in force in the United Kingdom;
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- (ii) in the case of Cyprus,
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- (a) any individual possessing the nationality or citizenship of Cyprus; and
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- (b) any legal person, partnership or association deriving its status as such from the laws in force in Cyprus;
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- k) the term ‘business’ includes the performance of professional services and of other activities of an independent character;
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- l) the term ‘pension scheme’ means any scheme or other arrangement which:
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- (i) is generally exempt from income taxation; and
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- (ii) operates to administer or provide pension or retirement benefits or to earn income for the benefit of one or more such arrangements.
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- 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 or the competent authorities agree to a different meaning pursuant to the provisions of Article 25, have the meaning that it has at that time under the law of that State for the purposes of the taxes to which this 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.