background image
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 term "Mexico" means the United Mexican States and, when used in a geographical sense, means the territory of the United Mexican States including inland waters, its airspace, the territorial sea and any area outside the territorial sea upon which, in accordance with International Law and on application of its domestic legislation, Mexico exercises, or may exercise in the future, jurisdiction or sovereign rights with respect to the seabed, its subsoil and superjacent waters, and their natural resources;
  • (b) the term the "United Arab Emirates" means the United Arab Emirates and, 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, subsoil, in connection with the exploration or for the exploitation of natural resources by virtue of its law and International Law;
  • (c) the terms "a Contracting State" and "the other Contracting State" mean Mexico or the United Arab Emirates, as the context requires;
  • (d) the term "person" includes an individual, an estate, a trust, a partnership, a company and any other body of persons;
  • (e) the term "national" means:
    • (i) any individual possessing the nationality of a Contracting State;
    • (ii) any legal person, partnership or association or other entity deriving its status as such from the laws in force in a Contracting State or of a political subdivision or a local government thereof;
  • (f) the term "company" means anybody corporate or any entity that is treated as a body corporate for tax purposes;
  • (g) the term "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 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 of a Contracting State, except when the ship or aircraft is operated solely between places in the other Contracting State;
  • (k) the term "qualified government entity" means, Central Bank of a Contracting State and any person, agency, institution, authority, fund, wholly owned by a Contracting State or any political subdivision or local government thereof;
  • (l) the term "competent authority" means:
    • (i) in the case of Mexico, the Ministry of Finance and Public Credit;
    • (ii) in the case of the United Arab Emirates, 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 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.