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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.


General Definitions

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

  • (a) the term "Ecuador" refers to the Republic of Ecuador. This term, when used in a geographical sense, means its national territory, including the territorial sea thereof, subsoil and other territories over which Ecuador exercises sovereignty, sovereign rights or jurisdiction in accordance with its local and international laws;
  • (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, sea bed, subsoil, in connection with the exploration for or the exploitation of natural resources by virtue of its law and international law,
  • (c) The expressions “a State”, “a Contracting State” and “the other Contracting State” mean, as the context requires so, Ecuador or the United Arab Emirates;
  • (d) The term “person” includes an individual, a company and any other body of persons;
  • (e) The term “company” means any juridical person or entity that -according to the domestic law- is treated as juridical person for tax purposes;
  • (f) 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;
  • (g) 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;
  • (h) The term “tax” means the Ecuadorian tax or the United Arab Emirates tax, as the context requires;
  • (i) The term “competent authority” means:
    • (i) in the case of Ecuador, the General Director of the Internal Revenue Service (Servicio de Rentas Internas);
    • (ii) in the case of the United Arab Emirates: the Minister of Finance or his authorized representative;
  • (j) The term “national” means:
    • (i) any individual possessing the nationality of a Contracting State; or
    • (ii) any legal person or association deriving its status as such from the laws in force in a Contracting State.

(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 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.