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HMRC internal manual

Double Taxation Relief Manual

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HM Revenue & Customs
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DT: Philippines: double taxation agreement, Article 3: General definitions

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

  1. 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;

  2. the term `Philippines` means the national territory comprising the Republic of the Philippines;

  3. the term `national` means:

(i) in relation to the United Kingdom, any citizen of the United Kingdom and Colonies who derives his status as such from his connection with the United Kingdom and any legal person, association or other entity deriving its status as such from the law in force in the United Kingdom;  
  
(ii) in relation to the Philippines, any citizen of the Philippines who derives his status as such and any legal person, association or other entity deriving its status as such from the law in force in the Philippines;
  1. the term `United Kingdom tax` means tax imposed by the United Kingdom being tax to which this Convention applies by virtue of the provisions of Article 2; the term `Philippine tax` means tax imposed by the Philippines being tax to which this Convention applies by virtue of the provisions of Article 2;

  2. the term `tax` means United Kingdom tax or Philippine tax, as the context requires;

  3. the terms `a Contracting State` and `the other Contracting State` mean the United Kingdom or the Philippines, as the context requires;

  4. the term `person` comprises an individual, a company and any other body of persons;

  5. the term `company` means any body corporate or any entity which is treated as a body corporate for tax purposes;

  6. 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;

  7. 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 the Philippines the Secretary of Finance or his duly authorised representative.

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