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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.

ARTICLE 4

General Definitions

(1) For the purposes of this Convention, unless the context otherwise requires:

  • (a) the terms "a Contracting State" and "the other Contracting State" mean United Arab Emirates or Andorra, as the context requires;
  • (b) the term "United Arab Emirates" when used in a geographical sense, means the territory of the United Arab Emirates which is under its sovereignty as well as the area outside the territorial water, airspace and submarine areas over which the United Arab Emirates exercises, sovereign and jurisdictional rights in respect of any activity carried on in its water, seabed, sup soil, in connection with the exploration for or the exploitation of natural resources by virtue of its law and international law;
  • (c) the term "Andorra" means the Principality of Andorra and, when used in a geographical sense means the territory of the Principality of Andorra;
  • (d) the term "person" includes an individual, a company and any other body of persons;
  • (e) the term "company" means any body corporate or any entity that is treated as a body corporate for tax purposes;
  • (f) the term "enterprise" applies to the carrying on of any business;
  • (g) the terms "enterprise of a Contracting State" and "enterprise of the other Contracting State" mean respectively an enterprise carried on by a resident of a Contracting State and an enterprise carried on by a resident of the other Contracting State;
  • (h) 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 State, except when the ship or aircraft is operated solely between places in the other Contracting State;
  • (i) the term “competent authority” means:
    • (i) In Andorra, the Minister of Finance or his authorized representative.
    • (ii) In the UAE, the Minister of Finance or an authorized representative of the Minister of Finance.
  • (j) the term “national”, in relation to a Contracting State, means:
    • (i) any individual possessing the nationality of that Contracting State; and
    • (ii) any person, partnership or association deriving its status as such from the laws in force in that Contracting State or of a political subdivision or a local government thereof;
  • (k) the term “business” includes the performance of professional services and of other activities of an independent character.
  • (l) the term “tax” means UAE tax or Andorran tax, as the content requires.
  • (m) the term “qualified government entity” means, Central bank of a Contracting State and any person, Agency, institution, authority, fund, enterprise, organization, or other entity owned or controlled directly or indirectly by a Contracting State or any political subdivision or local government thereof.

(2) As regards the application of the Convention at any time by a Contracting State, any term not defined therein shall, unless the context otherwise requires, have the meaning that it has at that time under the law of that State for the purposes of the taxes to which the Convention applies, any meaning under the applicable tax laws of that State prevailing over a meaning given to the term under other laws of that State.