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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) For the purposes of this Convention, unless the context otherwise requires:

  • (a) the term "Barbados" means the present territory of Barbados including the territorial sea and any maritime area situated outside the territorial sea of Barbados, which has been or might in the future be designated under the national law of Barbados in accordance with international law as an area within which Barbados may exercise its sovereign rights and jurisdiction to explore, exploit and preserve the seabed, subsoil and the natural resources;
  • (b) the term "San Marino" means the Republic of San Marino, and, when used in a geographical sense, the territory of the Republic of San Marino, including any other area within which the Republic of San Marino, in accordance with international law, exercises sovereign rights or jurisdiction;
  • (c) the term "company" means any body corporate or any entity which is treated as a body corporate for tax purposes;
  • (d) the term "competent authority" means:
    • (i) in Barbados, the Minister responsible for Finance or his authorised representative;
    • (ii) in the Republic of San Marino, the Ministry of Finance or its authorised representative, and, for the purpose of Article 26 "Exchange of Information", the Central Liaison Office of the Republic of San Marino;
  • (e) the terms "a Contracting State" and "the other Contracting State" mean San Marino or Barbados as the context requires;
  • (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 a ship or aircraft operated by an enterprise which has its place of effective management in a Contracting State, except when the ship or aircraft is operated solely between places in the other Contracting State;
  • (h) the term "person" includes an individual, a company and any other body of persons;
  • (i) the term "national" means any individual who is a citizen of a Contracting State, and any legal person, partnership and association deriving its status as such from the laws in force in a Contracting State;

(2) As regards the application of the Convention at any time by a Contracting State any term not defined therein shall, unless the context otherwise requires, have the meaning which it has at that time under the law of that State concerning the taxes to which the Convention applies.