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HMRC internal manual

Double Taxation Relief Manual

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

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

(a) the term `Cyprus` means the Republic of Cyprus, and includes any area adjacent to the territorial waters of Cyprus which in accordance with international law has been or may hereafter be designated, under the laws of Cyprus concerning the Continental Shelf, as an area within which the rights of Cyprus with respect to the sea bed and sub-soil and their natural resources may be exercised;

(b) 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;

(c) the terms `one of the Contracting States` and `the other Contracting State` mean the United Kingdom or Cyprus, as the context requires;

(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 `Cyprus tax` means tax imposed by Cyprus, being tax to which this Convention applies by virtue of the provisions of Article 2;

(e) the term `tax` means United Kingdom tax or Cyprus tax, as the context requires;

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

(g) the term `individual` means a natural person;

(h) the term `person` includes an individual, a company and a body of persons, but does not include a partnership;

(i) the terms `enterprise of one of the Contracting States` and `enterprise of the other Contracting State` mean respectively an enterprise carried on by a resident of one of the Contracting States and an enterprise carried on by a resident of the other Contracting State;

(j) the term `national` means:

(i) in relation to Cyprus:
(aa) any individual possessing the citizenship of Cyprus;
(bb) any legal person, partnership, association or other entity deriving its status as such from the law in force in Cyprus;
(ii) in relation to the United Kingdom:
(aa) any citizen of the United Kingdom and Colonies who derives his status as such from his connection with the United Kingdom;
(bb) any legal person, partnership, association or other entity deriving its status as such from the law of the United Kingdom;
(k) 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 Cyprus, the Commissioner of Income Tax or his authorised representative .

(2) In the application of this Convention by one of the Contracting States, 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.