For the purposes of this Agreement, unless the context otherwise requires:
the terms ‘‘a Contracting Party’’ means the Kingdom of the Netherlands or the Isle of Man, as the context requires; the term ‘‘Contracting Parties’’ means the Kingdom of the Netherlands and the Isle of Man;
the term ‘‘the Netherlands’’ means the part of the Kingdom of the Netherlands that is situated in Europe, including its territorial seas, and any area beyond the territorial sea within which the Netherlands, in accordance with international law, exercises jurisdiction or sovereign rights;
the term ‘‘Isle of Man’’ means the island of the Isle of Man;
the term ‘‘person’’ includes an individual, a company and any other body of persons;
the term ‘‘company’’ means any body corporate or any entity that is treated as a body corporate for tax purposes;
the term ‘‘resident of a Contracting Party’’ means any person, who under the law of that Party is liable to taxation therein by reason of his domicile, residence, place of effective management or any other criterion of a similar nature;
the term ‘‘enterprise of a Contracting Party’’ means an enterprise, carried on by a resident of a Contracting Party;
the term ‘‘international traffic’’ means any transport by a ship or aircraft operated by an enterprise that has its place of effective management in a Contracting Party, except when the ship or aircraft is operated solely between places in the other Contracting Party;
the term ‘‘income derived from the operation of ships or aircraft in international traffic’’ includes revenues, gross receipts and profits derived from:
- (i)
such operation of ships or aircraft for the transport of passengers or cargo;
- (ii)
the rental on a charter basis of ships or aircraft where the rental is ancillary to the operation of ships or aircraft in international traffic;
- (iii)
the sale of tickets or similar documents and the provision of services connected with such transport, either for the enterprise itself or for any other enterprise, where such sale of tickets or similar documents or provision of services is directly connected with or ancillary to the operation of ships or aircraft in international traffic;
- (iv)
the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers) used for the transport of goods or merchandise, where the use, maintenance or rental is directly connected with or ancillary to the operation of ships or aircraft in international traffic;
- (v)
interest on funds deposited directly in connection with the operation of ships or aircraft in international traffic.
- (i)
the term ‘‘competent authority’’ means:
- (i)
in the case of the Netherlands, the Minister of Finance or his authorised representative;
- (ii)
in the case of Isle of Man, the Chief Financial Off icer of the Treasury or his delegate;
- (i)