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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 Macedonia or United Arab Emirates, as the context requires;
  • (b) the term "Macedonia" means the territory of the Republic of Macedonia over which it has jurisdiction or sovereign rights for the purpose of exploring, exploiting, conserving and managing natural resources, pursuant to internal jurisdiction and international law;
  • (c) 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, sup soil, in connection with the exploration for or the exploration of natural resources by; virtue of its law and international law;
  • (d) the term "person" includes an individual, a partnership, 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 term "national" means:
    • (i) any individual possessing the nationality of a contracting State;
    • (ii) any legal person, partnership or association deriving its status as such from the laws in force in a Contracting State.
  • (g) the term "business" includes the performance of professional services and of other activities of an independent character;
  • (h) the term "enterprise" applies to the carrying on of any business;
  • (i) 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;
  • (j) 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;
  • (k) the term "tax" means the Macedonian tax or the UAE tax, as the context requires;
  • (l) the term "competent authority" means:
    • (i) in the case of Macedonia, the Ministry of Finance or its authorized representative;
    • (ii) in the case of the UAE, the Ministry of Finance or its authorized representative.

(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 Contracting 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.