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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 purpose of this Agreement, unless the context otherwise requires:

  • (i) the terms a "Contracting State" and "the other Contracting State" mean, as the context requires, the Republic of Indonesia or the United Arab Emirates;
  • (ii) the term "Indonesia" comprises the territory of the Republic of Indonesia as defined in its laws and the adjacent areas over which the Republic of Indonesia has sovereignty, sovereign rights or jurisdiction in accordance with the provisions of the United Nations Convention on the Law of the Sea, 1982;
  • (iii) the term "United Arab Emirates" means the United Arab Emirates and, when used in the geographical sense, means its territory, including islands, territorial sea, and any other area in the sea or in the air within which the United Arab Emirates exercises under its law and in conformity with international law, sovereign rights or its jurisdiction;
  • (iv) the term "tax" means Indonesian tax or United Arab Emirates tax as the context requires:
  • (v) the term "person" includes an individual, a company, or any other body of persons;
  • (vi) the term "company" means any body corporate or any entity which is treated as a body corporate for tax purposes;
  • (vii) 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;
  • (viii) the term "national" means all individuals possessing the nationality of a Contracting State and 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 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:

  • (i) in the case of the Republic of Indonesia, the Minister of Finance or his authorised representative; and
  • (ii) in the case of the United Arab Emirates, 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.