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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 3

General Definitions

(1) For the purposes of this Agreement, unless the context otherwise requires:

  • (a) the term "Singapore" means the Republic of Singapore and, when used in a geographical sense, includes its land territory, internal waters and territorial sea, as well as any maritime area situated beyond the territorial sea which has been or might in the future be designated under its national law, in accordance with international law, as an area within which Singapore may exercise sovereign rights or jurisdiction with regards to the sea, the seabed, the subsoil and the natural resources;
  • (b) the term "San Marino" means 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 "person" includes an individual, a company and any other body of persons;
  • (d) the term "company" means any body corporate or any entity that is treated as a body corporate for tax purposes;
  • (e) 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;
  • (f) 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;
  • (g) the term "competent authority" means:
    • (i) in Singapore, the Minister for Finance or his authorised representative;
    • (ii) in San Marino, the Minister of Finance or his authorised representative and, for the purposes of Article 25 "Exchange of Information", the Central Liaison Office of the Republic of San Marino;
  • (h) the term "national", in relation to a Contracting State, means:
    • (i) any individual possessing the nationality or citizenship of that Contracting State; and
    • (ii) any legal person, partnership or association deriving its status as such from the laws in force in that Contracting State.

(2) As regards the application of the Agreement at any time by a Contracting State, any term not defined therein shall, unless the context otherwise requires, have the meaning that it has at that time under the law of that State for the purposes of the taxes to which the Agreement applies, any meaning under the applicable tax laws of that State prevailing over a meaning given to the term under other laws of that State.