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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) In this Convention, unless the context otherwise requires:

  • (a) The Term "U.A.E" means the United Arab Emirates and, in a geographical sense, means the territory and islands of the United Arab Emirates including its territorial sea and submarine areas as well as the exclusive economic zone and the continental shelf over which U.A.E exercises sovereign rights, in accordance with its internal law and with the international law, concerning the exploration and exploitation of the natural, biological and mineral resources existing in the sea waters, seabed and subsoil of these waters;
  • (b) the term "Italy" means the Republic of Italy and includes any area beyond the territorial waters of Italy which, in accordance with the laws of Italy concerning the exploration and exploitation of natural resources, may be designated as an area within which the rights of Italy, with respect to the seabed and subsoil and natural resources, may be exercised;
  • (c) the terms "a contracting Slate" and "the other Contracting State " Mean the
  • United Arab Emirates or Italy, as the context requires;
  • (d) the term "person" includes an individual and a company and any other body of persons;
  • (e) the term "company" means anybody corporate or any entity which is treated as a body corporate 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 which has its place of effective management in a Contracting State, except when the ship or aircraft is operated solely between places in the other Contracting State;
  • (h) the term "national" means:
    • (i) all individuals possessing the nationality of Contracting State;
    • (ii) all legal persons, partnerships and associations deriving their status as such from the laws in force in a Contracting State;
  • (i) the term "competent authority" means:
    • (i) in the case of the United Arab Emirates, the Minister of Finance and Industry or his authorized representative;
    • (ii) in the case of Italy, the Ministry of Finance.

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