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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.


General Definitions

(1) In the context of the present Convention, unless the context requires a different interpretation:

  • (a) the term "Czechoslovakia" implies the Socialist Republic of Czechoslovakia;
  • (b) the term "Tunisia" implies, the territory of the Republic of Tunisia and the zones adjacent to the territorial waters of Tunisia over which, in accordance with international law, Tunisia shall exercise its rights with respect to the sea-bed, the sea basement and its natural resources.
  • (c) the expressions, a "Contracting State" and the "other Contracting State" imply, according to the context, Czechoslovakia or Tunisia.
  • (d) the term "person" includes all individuals, companies and any other body of persons.
  • (e) the term "company" implies any body corporate or any other entity that is deemed as a body corporate for the purpose of taxation.
  • (f) the expressions "an enterprise of a Contracting State" and "an enterprise of the other Contracting State" respectively imply an enterprise owned by a resident of a Contracting State and an enterprise owned by a resident of the other Contracting State.
  • (g) the term "national" implies:
    • (i) any individual who possesses the nationality of a Contracting State;
    • (ii) any legal persons, partnership and associations of persons constituted in accordance to the laws in force in the Contracting State;
  • (h) the term "international traffic" implies transport carried out by a ship or aircraft owned by an enterprise and its place of effective management thereof is located in a Contracting State, except where the ship or aircraft is operated solely between places located in the other Contracting State;
  • (i) the expression "competent authority" implies:
    • (i) with respect to Czechoslovakia, the Ministry of Finance of the Socialist Republic of Czechoslovakia or its authorized representative thereof;
    • (ii) with respect to Tunisia, the Ministry of Finance or its authorized representative thereof.

(2) For the application of the present Convention by a Contracting State any term or expression that may not be otherwise defined shall, unless the context otherwise requires, the context with which it has been attributed at the moment the laws of the Contracting State regarding the taxes that apply to the present Convention, shall have the meaning which it has under the tax laws of that State concerning the taxes to which the Convention applies, unless otherwise implied.