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- For the purposes of this Convention, unless the context otherwise requires:
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- a)the term "State" means the Netherlands or Zimbabwe, as the context requires; the term "States" means the Netherlands and Zimbabwe;
- b)the term "the Netherlands" means the part of the Kingdom of the Netherlands that is situated in Europe including the part of the sea bed and its sub-soil under the North Sea, to the extent that that area in accordance with international law has been or may hereafter be designated under Netherlands laws as an area within which the Netherlands may exercise certain rights with respect to the exploration and exploitation of the natural resources of the sea bed or its sub-soil;
- c)the term "Zimbabwe" means the Republic of Zimbabwe;
- d)the term "person" includes an individual, a company, an estate, a trust 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;
- f)the terms "enterprise of one of the States" and "enterprise of the other State" mean respectively an enterprise carried on by a resident of one of the States and an enterprise carried on by a resident of the other State;
- g)the term "international traffic" means any transport by a ship or aircraft, including transport by container, operated by an enterprise which has its place of effective management in one of the States, except when the ship or aircraft is operated solely between places in the other State;
- h)the term "national" means:
- (i)in relation to the Netherlands, any individual possessing the personality of the Netherlands and any legal person, partnership or association deriving its status as such from the law in force in the Netherlands;
- (ii)in relation to Zimbabwe, any citizen of Zimbabwe and any legal person, partnership, association or other entity deriving its status as such from the law in force in Zimbabwe;
- i)the term "competent authority" means in the case of the Netherlands the Minister of Finance or his authorised representative and in the case of Zimbabwe the Commissioner of Taxes or his authorised representative.
- 2
- As regards the application of this Convention by one of the States any term not defined therein shall, unless the context otherwise requires, have the meaning which it has under the law of that State concerning the taxes to which this Convention applies.
