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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.

ARTICLE 3

General Definitions

(1) In this Convention unless the context otherwise requires:

  • (a) the term "Pakistan" used in the geographical sense means Pakistan as defined in the Constitution of the Islamic Republic of Pakistan and includes any area outside the territorial waters of Pakistan which under the laws of Pakistan and international law is an area within which Pakistan exercises sovereign rights and exclusive jurisdiction with respect to the natural resources of the seabed, subsoil and superjacent waters;
  • (b) the term " United Arab Emirates" means the United Arab Emirates and, used in geographical sense to the area in which the territory under its sovereignty as well as territorial, airspace and submarine areas over which the United Arab Emirates exercises in conformity with international law sovereign right including mainlands and islands under its jurisdiction.
  • (c) the terms "a Contracting State" and "the other Contracting State" mean Pakistan or the United Arab Emirates as the context requires;
  • (d) the term "tax" means Pakistan tax or the United Arab Emirates tax, as the context requires, but shall not include any amount which is payable in respect of any default or omission in relation to the taxes to which the Convention applies or which represents a penalty imposed relating to those taxes;
  • (e) the term "person" includes an individual, a company, and any other entity which is treated as a taxable unit under the taxation laws in force in the respective Contracting States;
  • (f) the term "company" means any body corporate or any entity which is treated as a company or body corporate under the taxation laws in force in the respective Contracting States;
  • (g) 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;
  • (h) the term "competent authority" means:
    • (i) in Pakistan, the Central Board of Revenue or its authorised representative;
    • (ii) in the U.A.E. the Ministry of Finance and Industry or its authorised representative.
  • (i) the term "national" means any individual, possessing the nationality of a Contracting State and any legal person, partnership or association deriving its status from the laws in force in the 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.

(2) As regards the application of this Convention by a Contracting State, any term not defined herein shall, unless the context otherwise requires, have the meaning which it has under the laws of that State concerning the taxes to which the Convention applies.