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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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DT: Sri Lanka: 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 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 the natural resources may be exercised;
(b) the term `Sri Lanka` means the Democratic Socialist Republic of Sri Lanka;
(c) the term `national` means:

(i) in relation to the United Kingdom, any citizen of the United Kingdom and Colonies, or any British subject not possessing that citizenship or the citizenship of any other Commonwealth country or territory, provided in either case he has the right of abode in the United Kingdom, and any legal person, partnership and association deriving its status as such from the law in force in the United Kingdom;
(ii) in relation to Sri Lanka, any natural person who, under the law in force in Sri Lanka, is a citizen of Sri Lanka, and any legal person, partnership and association deriving its status as such from the law in force in Sri Lanka;

(d) the term `tax` means United Kingdom tax or Sri Lanka tax, as the context requires;
(e) the terms `a Contracting State` and `the other Contracting State` mean the United Kingdom or Sri Lanka, 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 term `international traffic` includes traffic between places in one Contracting State in the course of a voyage which extends over more than one Contracting State;
(i) 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;
(j) 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 Sri Lanka the Commissioner General of Inland Revenue or his authorised representative.
(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 this Convention.