第1條
For the purposes of this Agreement, unless the context otherwise requires: (a) the term “Hong Kong Special Administrative Region” means any place where the tax laws of the Hong Kong Special Administrative Region of the People’s Republic of China apply; (b) the term “Romania” means the state territory of Romania, including its territorial sea and air space above them, over which Romania exercises sovereignty, as well as the contiguous zone, the continental shelf and the exclusive economic zone over which Romania exercises sovereign rights and jurisdiction, in accordance with its legislation and with the rules and principles of international law; (c) the term “business” also includes the performance of professional services and of other activities of an independent character; (d) the term “company” means any body corporate or any entity that is treated as a body corporate for tax purposes; (e) the term “competent authority” means: (i) in the case of the Hong Kong Special Administrative Region, the Commissioner of Inland Revenue or his authorized representative; (ii) in the case of Romania, the Minister of Public Finance or his authorized representative; (f) the terms “a Contracting Party” and “the other Contracting Party” mean the Hong Kong Special Administrative Region or Romania, as the context requires; (g) the term “enterprise” applies to the carrying on of any business; (h) the terms “enterprise of a Contracting Party” and “enterprise of the other Contracting Party” mean respectively an enterprise carried on by a resident of a Contracting Party and an enterprise carried on by a resident of the other Contracting Party; (i) the term “international traffic” means any transport by a ship or aircraft operated by an enterprise of a Contracting Party, except when the ship or aircraft is operated solely between places in the other Contracting Party; (j) the term “national”, in relation to Romania, means any individual possessing the Romanian citizenship in accordance with the laws of Romania and any legal person, body of persons and any other entity set up and deriving its status as such from the laws in force in Romania; (k) the term “person” includes an individual, a company, a trust, a partnership and any other body of persons; (l) the term “tax” means the Hong Kong Special Administrative Region tax or Romanian tax, as the context requires.