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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 Agreement, unless the context otherwise requires:

  • (a) the terms "a Contracting State" and "the other Contracting State" mean Romania or the United Arab Emirates, as the context requires;
  • (b) the term "Romania" means the state territory of Romania, including its territorial sea and air space above them, over which Romania exercises sovereignty, as well as the contiguous zone, the continental shelf and the exclusive economic zone over which Romania exercises sovereign rights and jurisdiction, in accordance with its legislation and the rules and principles of international law;
  • (c) the term "United Arab Emirates" means the U.A.E. and used in a geographical sense, means the area in which the territory is under its 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 the natural resources;
  • (d) the term "person" includes an individual, a company and any other body of persons;
  • (e) the term "company" means any body corporate or any entity that is treated as a body corporate for tax purposes;
  • (f) 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;
  • (g) the term "national" means:
    • (i) in the case of Romania, any individual possessing the Romanian citizenship in accordance with the laws of Romania and any legal person, body of persons and any other entity set up and deriving its status as such from the laws in force in Romania;
    • (ii) in the case of the United Arab Emirates, all individuals possessing the nationality of United Arab Emirates in accordance with United Arab Emirates laws and any legal persons, partnership and other body corporate deriving its status as such from United Arab Emirates laws;
  • (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 such transport is operated solely between places in the other Contracting State;
  • (i) the term "competent authority" means:
    • (i) in the case of Romania, the Minister of Public Finance or its authorized representative;
    • (ii) in the case of the United Arab Emirates, the Minister of Finance or its authorized representative.
  • (j) the term "business" also includes the performance of professional services and of other activities of an independent character.

(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.