ARTICLE 3

General Definitions

(1) In this Convention, unless the context otherwise requires:

(a) (i) The term “United States” means the United States of America; and (ii) When used in a geographical sense, the term “United States” means the States thereof and the District of Columbia. Such term also includes

(A) the territorial sea thereof, and (B) the seabed and subsoil of the adjacent submarine areas beyond the territorial sea, over which the United States exercises sovereign rights in accordance with international law for the purpose of exploration and exploitation of the natural resources of such areas, but only to the extent that the person, property, or activity to which this Convention is being applied is connected with such exploration or exploitation. (b) (i)The term “Belgium” means the Kingdom of Belgium; and (ii) When used in a geographical sense the term “Belgium” means the territory of Belgium. Such term also includes

(A) the territorial sea thereof and (B) the seabed and subsoil of the adjacent submarine areas beyond the territorial sea over which Belgium exercises sovereign rights in accordance with international law, for the purpose of exploration and exploitation, of the natural resources of such areas, but only to the extent that the person, property, or activity to which this Convention is being applied is connected with such exploration or exploitation. (c) The, term “one of the Contracting States” or “the other Contracting State” means the United States or Belgium, as the context requires.

(d) The term “person” includes an individual, a partnership, a corporation, an estate, a trust, or any body of persons.

(e) (i) The term “United States corporation” or “corporation of the United States” means a corporation which is created or organized under the laws of the United States or any State thereof or the District of Columbia or any unincorporated entity treated as a United States corporation for United States tax purposes, provided that such corporation or entity is not a Belgian corporation for Belgian tax purposes; and

(ii) The term “Belgian corporation” or “corporation of Belgium” means any entity which under Belgian tax law

(A) is either a body corporate or is treated as a body corporate and

(B) is a resident of Belgium, provided that such entity is not a United States corporation for United States tax purposes. (f) The term “competent authority” means:

(i) In the case of the United States, the Secretary of the Treasury or his delegate, and

(ii) In the ease of Belgium, the competent authority according to Belgian legislation. (g) The term “State” means any National State, whether or not one of the Contracting States.

(2) Subject to paragraph (2) (d) of Article 25 (Mutual Agreement Procedure), any other term used in this Convention and not defined in this Convention shall, unless the context otherwise requires, have the meaning which it has under the laws of the Contracting State whose tax is being determined.