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Untd A Emirates - France Tax Treaty (as amended by 1993 protocol) — Orbitax Tax Hub

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 "one State" and "the other State" mean, as appropriate, the State of the United Arab Emirates or the French Republic;
  • (b) the term "person" includes an individual or a company;
  • (c) the term "company" means any body corporate governed by public or private law, including, in the case of the United Arab Emirates, the State of the United Arab Emirates, its political subdivisions and local authorities, or any entity regarded as a body corporate for the purposes of taxation;
  • (d) the terms "enterprise of one State", and "enterprise of the other State" mean respectively an enterprise carried on by a resident of one State and an enterprise carried on by a resident of the other State;
  • (e) the term "international traffic" means:
    • (i) any transport by a ship operated by an enterprise which has its place of effective management in one State, except when the ship is operated solely between places in the other State;
    • (ii) any transport any an aircraft operated by an enterprise of one State, except when the aircraft is operated solely between places in the other State;
  • (f) the term "competent authority" means:
    • (i) in the case of the United Arab Emirates, the Minister of Finance or his authorized representative;
    • (ii) in the case of the French Republic, the Minister in charge of the Budget or his authorized representative.

(2) As regards the application of the Convention by one State, any term not defined therein shall, unless the context otherwise requires, have the meaning which it has under the law of that State concerning the taxes to which the Convention applies.