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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 Convention, unless the context otherwise requires:

  • (a) the term "United Arab Emirates" means the State of the United Arab Emirates and, when used in its geographical sense, the regions and islands of the United Arab Emirates, which include the regional sea, the maritime area, the economic zone and the continental shelf and on which the United Arab Emirates exercises sovereign rights in accordance with its domestic laws and international law, with regard to the exploitation and exploration of natural resources found in sea waters, the seabed, and the subsoil.
  • (b) the term "Mauritania" is the entire territory of the Islamic Republic of Mauritania and includes the addition of the land territory, the territorial sea and beyond, areas of maritime space over which the Islamic Republic of Mauritania, in accordance with its legislation or international law, exercises rights of sovereignty or jurisdiction for the purposes of the exploration, exploitation, conservation and management of the natural resources of the seabed, the subsoil and the waters above it.
  • (c) the terms "Contracting State" and "the other Contracting State" shall mean United Arab Emirates or Mauritania, as the context requires.
  • (d) the term "corporation" shall mean any artificial person or independent entity which is treated as an artificial person for the purposes of tax.
  • (e) the terms "an enterprise of a Contracting State" and "an enterprise of the other Contracting State" shall mean respectively an enterprise managed by a resident in a Contracting State and an enterprise managed by a resident in the other Contracting State.
  • (f) the term "international transport" shall mean any transport by a ship or aircraft used by an enterprise situated in a Contracting State, except for ship or air transport which is done solely among places located only at the other Contracting State.
  • (g) the term "citizen" shall mean:
    • (i) any individual holds the nationality of a Contracting State.
    • (ii) any artificial person, general partnership or any other corporation featured by such status in accordance with the laws applicable in one of the Contracting States.
  • (h) the term "competent authority" shall mean:
    • (i) For UAE: Minister of Finance or his/her authorized representative;
    • (ii) For MR: Minister of Finance or his/her authorized representative.

(2) With regard to the application of this Convention in any time by a Contracting State, any term or phrase that is not defined herein, unless the context otherwise requires, shall have the same meaning applicable in the law of that State concerning the taxes to which the Convention applies.