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)
    • (i) the term "United Arab Emirates" means the United Arab Emirates and when used in a geographical sense, means the area in which the territory is under sovereignty as well as the territorial sea, airspace and submarine areas over which the United Arab Emirates exercises, in conformity with international law and the law of United Arab Emirates sovereign rights, including the mainland and islands under its jurisdiction in respect of any activity carried on in connection with the exploration for or the exploitation of natural resources;
    • (ii) the term "New Zealand" means the territory of New Zealand but does not include Tokelau or the Associated Self Governing States of the Cook Islands and Niue; it also includes any area beyond the territorial sea which by New Zealand legislation and in accordance with international law has been, or may hereafter be, designated as an area in which the rights of New Zealand with respect to natural resources may be exercised;
  • (b) the term "company" means anybody corporate or any entity that is treated as a body corporate for tax purposes;
  • (c) the term "competent authority" means:
    • (i) in the case of the United Arab Emirates, the Minister of Finance and Industry or an authorised representative;
    • (ii) in the case of New Zealand, the Commissioner of Inland Revenue or an authorised representative of the Commissioner;
  • (d) the terms "a Contracting State" and "the other Contracting State" mean the United Arab Emirates or New Zealand as the context requires;
  • (e) 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;
  • (f) 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 from a place or between places in the other Contracting State;
  • (g) the term "person" includes an individual, a company and any other body of persons.

(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 laws of that State for the purposes of the taxes to which the Agreement applies.