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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 and any area beyond the territorial sea over which the United Kingdom may exercise its sovereign rights in accordance with international law;
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- (b) the term ‘France’ means the European and overseas departments of the French Republic including the territorial sea, and any area beyond the territorial sea over which the French Republic has sovereign rights and exercises its jurisdiction in accordance with international law;
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- (c) the term ‘national’ means:
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- (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;
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- (ii) in relation to France, any individual possessing French nationality;
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- (d) the terms ‘a Contracting State’ and ‘the other Contracting State’ mean the United Kingdom or France, as the context requires;
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- (e) the term ‘person’ comprises an individual, a company and any other body of persons;
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- (f) the term ‘company’ means any body corporate or any entity which is treated as a body corporate for tax purposes;
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- (g) the term ‘enterprise’ applies to the carrying on of any business;
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- (h) 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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- (i) the term ‘international traffic’ means any transport by a ship, aircraft or railway vehicle operated by a resident of a Contracting State, except when the ship, aircraft or railway vehicle is operated solely between places in the other Contracting State;
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- (j) the term ‘competent authority’ means, in the case of the United Kingdom, the Commissioners for Her Majesty’s Revenue and Customs or their authorised representative, and, in the case of France, the Minister of Finance or his authorised representative;
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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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- 2. As regards the application of this 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 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.