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2.—(1) In this Arrangement, unless the context otherwise requires:
(a)The term “United Kingdom” means
(b)The term “Guernsey” means
(c)The terms “one of the territories” and “the other territory” mean
(d)The term “tax” means
(e)The term “person”
(f)The term “company”
(g)The terms “resident of the United Kingdom” and “resident of Guernsey” mean
(h)The terms “resident of one of the territories” and “resident of the other territory” mean
(i)The terms “United Kingdom enterprise” and “Guernsey enterprise” mean
(j)The term “industrial or commercial profits”
(k)The term “permanent establishment”
An enterprise of one of the territories shall not be deemed to have a permanent establishment in the other territory merely because it carries on business dealings in that other territory through a bona fide broker or general commission agent acting in the ordinary course of his business as such.
The fact that an enterprise of one of the territories maintains in the other territory a fixed place of business exclusively for the purchase of goods or merchandise shall not of itself constitute that fixed place of business a permanent establishment of the enterprise.
The fact that a company which is a resident of one of the territories has a subsidiary company which is a resident of the other territory or which is engaged in trade or business in that other territory (whether through a permanent establishment or otherwise) shall not of itself constitute that subsidiary company a permanent establishment of its parent company.
(2) Where under this Arrangement any income is exempt from tax in one of the territories if (with or without other conditions) it is subject to tax in the other territory, and that income is subject to tax in that other territory by reference to the amount thereof which is remitted to or received in that other territory, the exemption to be allowed under this Arrangement in the first-mentioned territory shall apply only to the amount so remitted or received.
(3) In the application of the provisions of this Arrangement by the United Kingdom or Guernsey, any term not otherwise defined shall, unless the context otherwise requires, have the meaning which it has under the laws of the United Kingdom, or, as the case may be, Guernsey, relating to the taxes which are the subject of this Arrangement.
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