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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 terms "a Contracting State" and "the other Contracting State" mean the United Arab Emirates or the Federal Democratic Republic of Ethiopia as the context requires;
  • (b) the term "United Arab Emirates", means the United Arab Emirates and when used in a geographical sense, means the area in which the territory is under its sovereignty as well as the territorial sea, airspace and submarine areas over which the United Arab Emirates exercises, in conformity with international law and the laws of the United Arab Emirates sovereign rights, including the mainland and islands under its jurisdiction in respect of any activity carried on in connection with the exploration for or the exploitation of natural resources;
  • (c) the term "Ethiopia" means the Federal Democratic Republic of Ethiopia; when used in a geographical sense, it means the national territory and any other area which in accordance with international law and the laws of Ethiopia is or may be designated as an area in which Ethiopia exercises sovereign rights or jurisdiction;
  • (d) the term "Tax" means UAE Tax or Ethiopian Tax as the context requires;
  • (e) the term "person" includes an individual, a company and any other body of persons;
  • (f) the term "company" means any body corporate or any entity that 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 any individual possessing the nationality of that Contracting State or any legal person, partnership, association or any other entity deriving its status as such from the laws in force in that Contracting State.

(2) 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;

(3) The term "competent authority" means:

  • (a) in the case of the UAE: the Minister of Finance or his authorized representative;
  • (b) in the case of Ethiopia: the Minister of Finance and Economic development 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 that it has at that time under the laws of that Contracting State for the purposes of the taxes to which the Agreement applies.