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ARTICLE 2

[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 the Russian Federation or the United Arab Emirates, as the context requires;
  • (b) the term "Russian Federation" means the territory of the Russian Federation and also its exclusive economic zone and continental shelf defined according to the UN Convention on the law of the seas (1982);
  • (c) the term "United Arab Emirates" means the territory of the United Arab Emirates which is under its sovereignty as well as the area outside the territorial waters, 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 for or the exploitation of natural resources by virtue of its law and international law;
  • (d) the term "company" means any body corporate or any entity which is treated as a body corporate for tax purposes;
  • (e) the term "resident of a Contracting State" for the purposes of this Agreement means any person other than individual who, under the laws of that Contracting State, is liable to tax therein by reason of its place of incorporation, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local government thereof.
  • Where by reason of the previous provisions of this sub-paragraph such a person is a resident of both Contracting States, then it shall be deemed to be a resident only of the Contracting State in which its place of effective management is situated;
  • (f) the term "political subdivisions" means, with respect to the Russian Federation, subjects of the Russian Federation, defined as such according to its legislation;
  • (g) the term "local government of the United Arab Emirates" means a government of any Emirate of the United Arab Emirates (Abu Dhabi, Dubai, Sharjah, Ras al Khaimah, Fujairah, Umm al Qaiwain and Ajman);
  • (h) the term "competent authorities" means:
    • (i) in the Russian Federation - the Ministry of Finance of the Russian Federation or its authorized representative;
    • (ii) in the United Arab Emirates - the Ministry of Finance of the United Arab Emirates or its authorized representative,
  • (i) the expression "Contracting State or its financial and investment institutions" mean:
    • (i) in the Russian Federation:
      • (1) the Government of the Russian Federation;
      • (2) the government of any subject of the Russian Federation;
      • (3) the Central Bank of the Russian Federation;
      • (4) any financial or investment organization, institution, agency or instrumentality wholly owned by the Russian Federation, by the Government of the Russian Federation or by the government of any subject of the Russian Federation;
      • (5) Pension fund of the Russian Federation;
    • (ii) in the United Arab Emirates:
      • (1) the Government of the United Arab Emirates;
      • (2) any local government of the United Arab Emirates (Abu Dhabi, Dubai, Sharjah, Ras al Khaimah, Fujairah, Umm al Qaiwain and Ajman);
      • (3) the Central Bank of the United Arab Emirates;
      • (4) the Abu Dhabi Investment Authority;
      • (5) Emirates Investment Authority;
      • (6) any financial or investment organization, institution, agency or instrumentality wholly owned by the Government of the United Arab Emirates or by any local government of the United Arab Emirates;
      • (7) state pension fund of the United Arab Emirates.
  • The competent authorities of the Contracting States may agree from time to time to extend the benefits provided for by this Agreement to any other similar entity wholly owned by any Contracting State, including its federal government or any government of the subject of the Russian Federation, or any local government of the United Arab Emirates.
  • This Agreement shall not affect the right of a Contracting State to benefit from tax incentives, exemptions and allowances provided for or, may be provided by the other Contracting State in accordance with its national laws and regulations.

(2) As regards the application of this Agreement by a Contracting State, any term not defined therein shall, unless the context otherwise requires, have the meaning which it has under the laws of that State concerning the taxes to which this Agreement applies, any meaning under applicable tax laws of that State prevailing over a meaning given to the term under other laws of that State.