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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.

ARTICLE 1

Scope of the Agreement

(1) This Agreement shall apply to persons who for the purposes of taxation are deemed to be residents of one or both of the Contracting States.

(2)

  • (a) This Agreement shall apply to the territory of each Contracting State, including its territorial sea, to its economic zone and its continental shelf, adjacent to the limits of its territorial sea, in respect of which it exercises, in conformity with international law, sovereign rights for the purposes of exploration and exploitation of natural resources of such areas.
  • (b) For the purposes of this Agreement, any reference to either Contracting State shall be deemed as reference to the territory of the respective State, including its territorial sea, to its economic zone and the regions of the continental shelf adjacent to the limits of the territorial sea of this State, which are mentioned in sub-paragraph (a).