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.
ARTICLE 3
General Definitions
(1) For the purposes of this Convention, unless the context otherwise requires:
- (a) The terms "a Contracting State" and "the other Contracting State" mean, according to the context, the Federal Republic of Germany or the Republic of the Ivory Coast, and, when used in a geographical sense, the territory to which the tax laws of the State concerned apply;
- (b) The term "person" includes an individual, a company, and any other bodies of persons;
- (c) The term "company" means any body corporate or entity which is treated as a body corporate for tax purposes;
- (d) 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;
- (e) The term "nationals" means:
- (aa) In the case of the Federal Republic of Germany, all Germans within the meaning of paragraph (1) of Article 116, of the Basic Law for the Federal Republic of Germany and all bodies corporate, all partnerships and all other groups of persons constituted in accordance with the laws in force in the Federal Republic of Germany;
- (bb) In the case of the Ivory Coast, all individuals possessing Ivorian nationality and all bodies corporate, partnerships and associations constituted in accordance with the laws in force in the Republic of the Ivory Coast.
- (f) The term "competent authorities" means:
- (i) In the case of the Federal Republic of Germany, the Federal Minister of Finance;
- (ii) In the case of the Ivory Coast, the Minister of Finance or his representative.
(2) As regards the application of this Convention 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 State concerning the taxes to which the Convention applies.