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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 this Agreement, unless the context otherwise requires:

  • (a) the term "Nigeria" means the Federal Republic of Nigeria including any area outside the territorial waters of the Federal Republic of Nigeria which in accordance with international law has been or may hereinafter be designated, under the laws of the Federal Republic of Nigeria concerning the Continental Shelf, as an area within which the rights of the Federal Republic of Nigeria with respect to the seabed and subsoil and their natural resources may be exercised;
  • (b) the term "Czechoslovakia" means the Czechoslovak Socialist Republic;
  • (c) the terms "a Contracting State" and "the other Contracting State" mean Czechoslovakia and Nigeria as the context requires;
  • (d) the term "person" comprises 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 under the laws of each Contracting State;
  • (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 and nationality of a Contracting State;
    • (ii) any legal person, partnership or association deriving its status as such from the law in force in a Contracting State;
  • (h) the term "international traffic" means any transport by a ship or aircraft operated by an enterprise of a Contracting State, except when the ship or aircraft is operated solely between places in the other Contracting State;
  • (i) the term "competent authority" means:
    • (i) in the case of Czechoslovakia, the Minister of Finance of the Czechoslovak Socialist Republic or his authorised representative;
    • (ii) in the case of Nigeria, the Minister of Finance or his authorised representative.

(2) In the application of this Agreement by a Contracting State, any term not defined shall, unless the context otherwise requires, have the meaning which it has under the laws of that Contracting State relating to the taxes which are the subject of this Agreement.