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.


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, as the context requires, the Czech Republic or the United Arab Emirates;
  • (b) the term "Czech Republic" means the territory over which, under Czech legislation and in accordance with international law, the sovereign rights of the Czech Republic are exercised;
  • (c) the term "United Arab Emirates", when used in a geographical sense, means the territory of the United Arab Emirates including its territorial waters, islands, airspace, seabed, subsoil and their natural resources over which the United Arab Emirates exercises in conformity with international law its sovereign rights;
  • (d) the term "tax" means U.A.E. tax or Czech tax as the context requires;
  • (e) the term "person" includes an individual, a company, or any other body of persons legally set up in either of the Contracting States;
  • (f) the term "company" means any body corporate or any entity which is treated as a body corporate for tax purposes;
  • (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 "national" means:
    • (i) all individuals possessing the nationality of a Contracting State; and
    • (ii) all legal persons, partnerships and associations deriving their status as such from the law in force in a Contracting State.

(2) The term "international traffic" means any transport by ships, boats, or aircraft operated by an enterprise of a Contracting State except when the ship, boat, or aircraft is operated solely between places in the other Contracting State.

(3) The term "competent authority" means:

  • (a) in the case of U.A.E., the Minister of Finance and Industry or his authorised representative; and
  • (b) in the case of the Czech Republic, the Minister of Finance or his authorised representative.

(4) In the application of this Agreement by either of the Contracting States, any term not defined therein shall-unless the context otherwise requires-have the meaning which it has under the laws of that State concerning the taxes to which the Agreement applies.