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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 Definition

(1) For the purposes of this Agreement, unless the context otherwise requires:

  • (a) The terms "a Contracting State" and "the other Contracting State" mean United Arab Emirates or Maldives, as the context requires;
  • (b) 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, seabed, supsoil, in connection with the exploration for or the exploitation of natural resources by virtue of its law and international law;
  • (c) The term "the Maldives" means the Republic of Maldives, and when used in a geographical sense, it means the territory of the Maldives and includes its territorial sea, continental shelf, seabed, subsoil (and their natural resources) and airspace, as well as any maritime zone in which the Maldives has sovereign rights, other rights and jurisdiction, according to the law of the Maldives and in accordance with international law, including the United Nations Convention on the Law of the Sea;
  • (d) The term "person" includes an. individual, a company and any other body of persons;
  • (e) The term "national" in relation to a Contracting State means:
    • (1) any individual possessing the nationality or citizenship of that Contracting State; and
    • (2) any legal person, partnership or association deriving its status as such from the laws in force in that Contracting State;
  • (f) The term "company" means any body corporate or any entity that is treated as a body corporate for tax purposes;
  • (g) A pension scheme means any plan, scheme, fund, trust, or other arrangement established in a Contracting State, is generally exempt from tax in that State and operated principally either to administer or provide pension or retirement benefit or to earn income for the benefit of one or more such arrangements;
  • (h) 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;
  • (i) The term "international traffic" means any transport by a ship or aircraft operated by an enterprise of a contracting State that 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;
  • (j) The term "business" includes the performance of professional services and of other activities of an independent character.
  • (k) The term "qualified government entity" means, Central bank of a Contracting State and any person, Agency, financial institution, authority, fund, enterprise, organization, or other entity wholly owned directly or indirectly by a contracting State or any political subdivision or local government thereof.
  • (l) The term "tax" means UAE tax or Maldives tax, as the context requires;
  • (m) The term "competent authority" means:
    • (1) in the case of the UAE the Minister of Finance or his authorized representative;
    • (2) in the case of the Maldives, the Maldives Inland Revenue Authority, or its authorised 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 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.