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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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DT: Barbados: double taxation agreement, Article 2: General definitions

(1) In this Agreement, unless the context otherwise requires:
(a) `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) `Barbados` means the island of Barbados and the territorial waters thereof including any area outside such territorial waters which in accordance with international law and the laws of Barbados is an area within which the rights of Barbados with respect to the sea bed and sub-soil and their natural resources may be exercised;

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

(d) `a Contracting State` and `the other Contracting State` mean the United Kingdom or Barbados, as the context requires;

(e) `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;

(f) `international traffic` includes traffic between places in one country in the course of a voyage which extends over more than one country;

(g) `national` means:

(i) in relation to the United Kingdom:

(aa) any citizen of the United Kingdom and Colonies who derives his status as such from connection with the United Kingdom;

(bb) any legal person, association or other entity deriving its status as such from the law of the United Kingdom;

(ii) in relation to Barbados:

(aa) any individual who is a citizen of Barbados;

(bb) any legal person, partnership or association deriving its status as such from the law of Barbados;

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

(i) `tax` means United Kingdom tax or Barbados tax, as the context requires;

(j) `taxation authorities` means, in the case of the United Kingdom, the Commissioners of Inland Revenue or their authorised representative; in the case of Barbados, the Commissioner of Inland Revenue or his authorised representative.

(2) In the application of the provisions of this Agreement 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 Agreement.