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HMRC internal manual

Double Taxation Relief Manual

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HM Revenue & Customs
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DT: Sudan: 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 their natural resources may be exercised;
(b) the term `the Sudan` means the Democratic Republic of the Sudan, including any area outside the territorial sea of the Democratic Republic of the Sudan which in accordance with international law has been or may hereafter be designated, under the laws of the Democratic Republic of the Sudan concerning the Continental Shelf, as an area within which the rights of the Democratic Republic of the Sudan with respect to the sea bed and sub-soil and their natural resources may be exercised;
(c) the term `national` means:

(i) in relation to the United Kingdom all citizens of the United Kingdom and Colonies who derive their status as such from their connection with the United Kingdom and all legal persons, partnerships and associations deriving their status as such from the law in force in the United Kingdom;
(ii) in relation to the Sudan, all citizens of the Democratic Republic of the Sudan who derive their status as such from their connection with the Democratic Republic of the Sudan and all legal persons, partnerships and associations deriving their status as such from the law in force in the Democratic Republic of the Sudan.

(d) 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 `Sudan tax` means tax imposed by the Sudan, being tax to which this Convention applies by virtue of the provisions of Article 2;
(e) the term `tax` means United Kingdom tax or Sudan tax, as the context requires;
(f) the terms `a Contracting State` and `the other Contracting State` mean the United Kingdom or the Sudan, as the context requires;
(g) the term `person` comprises an individual, a company and any other body or persons;
(h) the term `company` means any body corporate or any entity which is treated as a body corporate for tax purposes;
(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 the Sudan the Director of Taxation 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.