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ARTICLE 3 General Definitions

ARTICLE 3
General Definitions

 

1. For the purposes of this Agreement, unless the context otherwise requires:

a) the term "the Democratic People's Republic of Korea (the DPRK)" means the territory of the Democratic People's Republic of Korea as well as its continental shelf and exclusive economic zone defined in accordance with the UN Convention on the Law of the Sea;

b) the term "the Russian Federation (Russia)" means the territory of the Russian Federation as well as its continental shelf and exclusive economic zone defined in accordance with the UN Convention on the Law of the Sea;

c) the terms "a Contracting State", "one of the Contracting States" and "the other Contracting State" mean the DPRK or Russia, as the context requires;

d) the term "person" includes an individual, a company and any other body of persons;

e) the term "company" means any body corporate or any entity which is treated as a body corporate for tax purposes;

f) 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;

g) the term "national" means:

(i) any individual possessing the citizenship of a Contracting State;

(ii) any legal person, partnership or association deriving its status as such from the laws in force in a Contracting State;

h) the term "international traffic" means any transport by a ship, aircraft or road transport vehicle operated by a resident of a Contracting State, except when such transport is operated solely between places in the other Contracting State;

i) the term "competent authority" means:

(i) in the case of the DPRK - the Ministry of Finance or its authorised representative;

(ii) in the case of Russia - the Ministry of Finance of the Russian Federation or its authorised representative.

2. As regards the application of this Agreement by a Contracting State any term not defined therein shall, unless the context otherwise requires, have the meaning which it has under the laws of that Contracting State concerning the taxes to which the Agreement applies.