Article 3 General Definitions

(1) For the purposes of this Agreement, unless the context otherwise requires: a) the term “Federal Republic of Germany” means the territory of the Federal Republic of Germany, as well as the area of the sea-bed, its subsoil and the superjacent water column adjacent to the territorial sea, insofar as the Federal Republic of Germany exercises there, in conformity with international law and its national legislation, sovereign rights and jurisdiction to explore and exploit the natural resources; b) the term “Singapore” means the territory of the Republic of Singapore, as well as the area of the sea-bed, its subsoil and the superjacent water column adjacent to the territorial sea, insofar as the Republic of Singapore exercises there, in conformity with international law and its national legislation, sovereign rights and jurisdiction to explore and exploit the natural resources; c) the terms “a Contracting State” and “the other Contracting State” mean the Federal Republic of Germany or Singapore as the context requires; d) the term “person” includes an individual, a company and any other body of persons; e) the term “company” means any body corporate or any entity which is treated as a body corporate for tax purposes; f) the terms “enterprise of a Contracting State” and “enter- prise 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 Con- tracting State; g) 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; h) the term “national” means: aa) in respect of the Federal Republic of Germany: any German within the meaning of the Basic Law of the Federal Republic of Germany or any legal person, partnership or association deriving its status as such from the laws in force in the Federal Republic of Ger- many; bb) in respect of Singapore: any individual possessing the nationality of Singapore or any legal person, partnership or association deriving its status as such from the laws in force in Singapore; i) the term “competent authority” means: aa) in the case of the Federal Republic of Germany, the Federal Ministry of Finance or the agency to which it has delegated its powers; bb) in the case of Singapore, the Minister for Finance or his authorised representative.

(2) As regards the application of this Agreement 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 Agreement 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.