Artikel I

It is understood that for the purposes of this Convention a Contracting State, its political subdivisions or local authorities thereof, an instrumentality of that State, political subdivision or authority as well as a pension fund or charitable organisation recognized as such in a Contracting State and of which the income is generally exempt from tax in that State, shall be regarded as resident of that State. As recognized pension fund shall be regarded, in the case of Estonia, any pension fund established under the laws of Estonia and in the case of the Netherlands, any pension fund recognized and controlled according to statutory provisions.