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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 "Portugal" when used in a geographical sense comprises the territory of the Portuguese Republic in accordance with the International Law and the Portuguese legislation, including its territorial sea, as well as those maritime areas adjacent to the outer limit of the territorial sea, comprising the seabed and subsoil thereof, over which the Portuguese Republic exercises sovereign rights or jurisdiction;
  • (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 connection with the exploration for, or the exploitation of, natural resources by virtue of international law;
  • (c) the terms "a Contracting State" and "the other Contracting State" mean Portugal or the United Arab Emirates as the context requires;
  • (d) the term "tax" means Portuguese tax or United Arab Emirates tax, as the context requires;
  • (e) the term "person" includes an individual, a company and any other body of persons;
  • (f) the term "company" means any-body corporate or any entity that is treated as a body corporate for tax purposes;
  • (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 "international traffic" means any transport by a ship or aircraft operated by an enterprise 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;
  • (i) the term "competent authority" means:
    • (i) in Portugal: the Minister of Finance, the Director General of Taxation (Director-Geral dos Impostos) or their authorised representative;
    • (ii) in the United Arab Emirates: the Minister of Finance or an authorised representative of the Minister of Finance;
  • (j) the term "national", in relation to a Contracting State, means:
    • (i) any individual possessing the nationality or citizenship of that Contracting State; and
    • (ii) any legal person, partnership or association deriving its status as such from the laws in force in that Contracting State.

(2) As regards the application of the Convention 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 Convention 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.