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HMRC internal manual

Double Taxation Relief Manual

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HM Revenue & Customs
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DT: Thailand: 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 subsoil and their natural resources may be exercised;
(b) the term `Thailand` means the Kingdom of Thailand and any area adjacent to the territorial waters of the Kingdom of Thailand which by Thai legislation, and in accordance with international law? has been or may hereafter be designated as an area within which the rights of the Kingdom of Thailand with respect to the sea bed and subsoil and their natural resources may be exercised;
(c) the term `nationals` means:

(i) in relation to the United Kingdom, citizens of the United Kingdom and Colonies and British subjects not possessing that citizenship or the citizenship of any other Commonwealth country or territory provided in all cases they are patrial within the meaning of the Immigration Act 1971(a), and all legal persons, partnerships, associations or other entities deriving their status as such from the law in force in the United Kingdom;
(ii) in relation to Thailand, all individuals possessing the nationality of Thailand and all legal persons, partnerships and associations deriving their status as such from the law in force in Thailand;

(d) the term `tax` means United Kingdom tax or Thai tax, as the context requires;
(e) the terms `a Contracting State` and `the other Contracting State` mean the United Kingdom or Thailand, as the context requires;
(f) the term `person` comprises an individual, a company and any body of persons which is treated as an entity for tax purposes;
(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 `competent authority` means, in the case of the United Kingdom the Commissioners of Inland Revenue or their authorised representative, and in the case of Thailand, the Minister of Finance or his authorised representative;
(j) the term `international traffic` means any transport by a ship or aircraft operated by an enterprise which 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;
(k) the term `political subdivision`, in relation to the United Kingdom, includes Northern Ireland.

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 laws of that Contracting State relating to the taxes which are the subjectof this Convention.