background image
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 3

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 Argentina or United Arab Emirates as the context requires;
  • (b) the term "Argentina" means the territory subjected to the sovereignty of the Argentine Republic, in accordance with its constitutional and legal provisions and the term "United Arab Emirates" when used in 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, subsoil, in connection with the exploration for or the exploitation of natural resources by virtue of its law and international law;
  • (c) the term "person" includes an individual, a company and any other body of persons;
  • (d) the term "company" means any body corporate or any entity which is treated as a body corporate for tax purposes;
  • (e) 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;
  • (f) the term "international traffic" means any transport by a ship or aircraft operated by a resident of a Contracting State, except when the ship or aircraft is operated solely between places in the other Contracting State;
  • (g) the term "national" means:
    • (i) any individual possessing the nationality of a Contracting State; and
    • (ii) any legal person, partnership and association deriving its status as such from the laws in force in a Contracting State.
  • (h) the term "competent authority" means:
    • (i) in the case of Argentina, the Ministry of Treasury and Public Finances, Secretariat of Treasury (Ministerio de Hacienda y Finanzas Públicas, Secretaría de Hacienda); and
    • (ii) in the case of United Arab Emirates, the Ministry of Finance or its authorized representative.

(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.