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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, 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;
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- (b) the term ‘Italy’ means the Italian Republic and includes any area beyond the territorial waters of Italy which, in accordance with the laws of Italy concerning the exploration and exploitation of natural resources, may be designated as an area within which the rights of Italy with respect to the sea bed and sub-soil and their natural resources may be exercised;
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- (c) the terms ‘a Contracting State’ and ‘the other Contracting State’ mean the United Kingdom or Italy, as the context requires;
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- (d) 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;
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- (e) the term ‘company’ means any body corporate or any entity which is treated as a body corporate for tax purposes;
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- (f) 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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- (g) 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; and any legal person, partnership, association or other entity deriving its status as such from the law in force in the United Kingdom;
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- (ii) in relation to Italy, any individual possessing the citizenship of Italy and any legal person, partnership and association deriving its status as such from the law in force in Italy;
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- (h) 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;
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- (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 Italy, the Ministry of Finance;
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- (j) the term ‘tax’ means United Kingdom tax or Italian tax, as the context requires.
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- (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 the Convention.