Artikel 3 Verdrag tussen de Regering van het Koninkrijk der Nederlanden en de Regering van de Arabische Republiek Egypte tot het vermijden van dubbele belasting en het voorkomen van het ontgaan van belasting met betrekking tot belastingen naar het inkomen

Article 3 General definitions 1 For the purposes of this Agreement, unless the context otherwise requires: a) the term “a Contracting State” means the Kingdom of the Netherlands (the Netherlands) or the Arab Republic of Egypt (Egypt), as the context requires; the term “Contracting States” means the Kingdom of the Netherlands (the Netherlands) and the Arab Republic of Egypt (Egypt); b) the term “the Netherlands” means the part of the Kingdom of the Netherlands that is situated in Europe, including its territorial sea, and any area beyond the territorial sea within which the Netherlands, in accordance with international law, exercises jurisdiction or sovereign rights with respect to the sea bed, its sub-soil and its superjacent waters, and their natural resources; c) the term “Egypt” means the Arab Republic of Egypt, and when used in a geographical sense, the term “Egypt” includes: (i) the territorial seas thereof, and (ii) the seabed and subsoil of the submarine areas adjacent to the coast thereof, but beyond the territorial sea, over which Egypt exercises sovereign rights, in accordance with international law for the purpose of exploration and exploitation of the natural resources of such area, but only to the extent that the person, property or activity to which the Agreement is being applied is connected with such exploration or exploitation; 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 that is treated as a body corporate for tax purposes; 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; g) the term “international traffic” means any transport by a ship or aircraft operated by an enterprise that 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: (i) any individual possessing the nationality of a Contracting State; (ii) any legal person, partnership and association deriving its status as such from the laws in force in a Contracting State; i) the term “competent authority” means: (i) in the Netherlands the Minister of Finance or his duly authorized representative; (ii) in Egypt the Minister of Finance or his duly authorized representative. 2 As regards the application of the Agreement at any time by a Contracting State any term not defined therein shall, unless the context otherwise requires, have the meaning which 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.