Article 3 GENERAL DEFINITIONS

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

(a) the term "Namibia" means the Republic of Namibia and when used in a geographical sense, includes the territorial sea as well as the exclusive economic zone and the continental shelf, insofar as Namibia exercises sovereign rights in accordance with its internal law and subject to international law, concerning the exploration and exploitation of the sea-bed and its subsoil and the superjacent water;

(b) the term "the Russian Federation (Russia)", means the territory of the Russian Federation, as well as its exclusive economic zone and continental shelf as they are defined in the UN Convention on the Law of the Sea 1982;

(c) the terms "a Contracting State" and "the other Contracting State" mean Namibia 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 "international traffic" means any transport by ship or aircraft operated by a resident of a Contracting State, except when the ship or aircraft is operated solely between places in the other Contracting State;

(h) the term "national" means:

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

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

(i) the term "competent authority" means:

(i) in the case of Namibia, the Permanent Secretary in the Ministry of Finance who is the Chief Executive Officer and Administrator of Namibian tax laws or his authorised representative;

(ii) in the case of Russia, the Ministry of Finance or its authorised representative.

2. As regards the application of the Convention by a Contracting State, reference to the masculine includes the feminine and any term not defined therein shall, unless the context otherwise requires, have the meaning which it has under the law of that State concerning the taxes to which this Convention applies.