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HMRC internal manual

Double Taxation Relief Manual

DT: Luxembourg: double taxation agreement, Article 3: General definitions

(1) In this Convention, unless the context otherwise requires:

(a) the term ` United Kingdom ` means Great Britain and Northern Ireland, including any area outside the territorial sea of the United Kingdom which 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;

(b) the term ` Luxembourg ` means the Grand Duchy of Luxembourg;

(c) the terms ` a Contracting State ` and ` the other Contracting State ` mean the United Kingdom or Luxembourg, as the context requires;

(d) the term ` competent authority ` means, in the case of Luxembourg, the Ministre du Tresor or his authorised representative; in the case of the United Kingdom, the Commissioners of Inland Revenue or their authorised representative; and, in the case of any territory to which the Convention is extended under Article 31, the competent authority for the administration in such territory of the taxes to which the Convention applies;

(e) the term ` tax ` means United Kingdom tax or Luxembourg tax, as the context requires;

(f) the term ` person ` comprises an individual, a company and any other body of persons;

(g) the term ` company ` means any body corporate or any entity which is treated as a body corporate for tax purposes;

(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;

(i) the term ` profits of an enterprise ` includes rents or royalties in respect of cinematograph including television films;

(j) the term `international traffic` includes traffic between places in any State in the course of a voyage which extends over two or more States.

Article 3(2) was deleted by SI84/364, and Article 3(3) was renumbered Article 3(2).

(2) As regards the application of the Convention by a Contracting State any term nototherwise defined shall, unless the context otherwise requires, have the meaning which ithas under the laws of that Contracting State relating to the taxes which are the subjectof the Convention.