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- (1) For the purposes of this Agreement, 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 subsoil and their natural resources may be exercised
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- (b) the term ‘Singapore’ means the Republic of Singapore
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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; 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 Singapore, any individual possessing the nationality of Singapore; and any legal person, partnership or association deriving its status as such from the laws in force in Singapore
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- (d) the terms ‘a Contracting State’ and ‘the other Contracting State’ mean the United Kingdom or Singapore, as the context requires
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- (e) the term ‘person’ includes 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 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 case of the United Kingdom, the Commissioners for Her Majesty’s Revenue and Customs or their authorised representative
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- (ii) in the case of Singapore, the Minister for Finance or his authorised representative
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- (j) the term ‘tax’ means United Kingdom or Singapore tax as the context requires
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- (k) the term ’fiscal year’ means:
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- (i) in the case of the United Kingdom:
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- - for the purposes of the Income Tax, a year of assessment beginning on 6 April in one year and ending on 5 April in the following year
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- - for the purposes of the Corporation Tax, a year of assessment beginning on 1 April in one year and ending on 31 March in the following year; and
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- (ii) in the case of Singapore, a calendar year
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- (2) For the purposes of Articles 10, 11 and 12 of this Agreement, a trustee subject to tax in a Contracting State in respect of dividends, interest or royalties shall be deemed to be the beneficial owner of that interest or those dividends or royalties.
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- (3) As regards the application of this Agreement by a Contracting State any term not defined therein shall, unless the context otherwise requires, have the meaning which it has under the laws of that Contracting State concerning the taxes to which this Agreement applies.