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ARTICLE 4

General Definitions

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

  • (a) the terms "a Contracting State" and "the other Contracting State" mean United Arab Emirates or Cyprus, 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, subsoil, in connection with the exploration for or the exploitation of natural resources by virtue of its law and international law;
  • (c) the term "Cyprus" means the Republic of Cyprus and, when used in a geographical sense, includes the national territory, the territorial sea thereof as well as any area outside the territorial sea, including the contiguous zone, the exclusive economic zone and the continental shelf, which has been or may hereafter be designated, under the laws of Cyprus and in accordance with international law, as an area within which Cyprus may exercise sovereign rights or jurisdiction;
  • (d) the term "person" includes an individual, a company and any other body of persons;
  • (e) the term "national" means:
    • (1) any individual possessing the nationaIity or citizenship of a Contracting State;
    • (2) any legal person, partnership or association deriving its status as such from the laws in force in a Contracting State;
  • (f) the term "company" means any body corporate or any entity that is treated as a body corporate for tax purposes;
  • (g) the term "enterprise" applies to the carrying on of any business;
  • (h) 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;
  • (i) the term "international traffic" means any transport by a ship or aircraft operated by an enterprise of a Contracting State, except when the ship or aircraft is operated solely between places in the other Contracting State;
  • (j) the term "business" includes the performance of professional services and of other activities of an independent character;
  • (k) the term "tax" means United Arab Emirates tax or Cyprus tax, as the context requires;
  • (l) the term "competent authority" means:
    • (1) in the case of the United Arab Emirates: the Minister of Finance or an authorized representative of the Minister of Finance;
    • (2) in the case of Cyprus: the Minister of Finance or his authorized representative.

(2) As regards the application of the Agreement 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 Contracting State for the purposes of the taxes to which the Agreement 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.