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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 terms "a Contracting State" and "the other Contracting State" shall mean, depending on the context, UAE or Republic of Sudan;
  • (b) the term "UAE" shall mean the region of UAE and when used in its geographical sense includes the territorial water, islands, economic zone, continental lands, airspace and natural resources over which UAE exercises its sovereign rights in accordance with its domestic laws and in accordance with international law;
  • (c) the term "Republic of Sudan" shall mean the region of Sudan Republic, its soil, islands, territorial water, economic zone, continental lands, and any other maritime area subject to the sovereignty of Sudan in accordance with the international law;
  • (d) the term "tax" shall mean, depending on the context, "UAE tax" or "Sudan tax";
  • (e) the term "person" shall mean any natural person, corporation or any other any entities established legally in either one of the Contracting States;
  • (f) the term "corporation" shall mean any body corporate or any entity that is treated as a body corporate for tax purposes;
  • (g) the terms "an enterprise of a Contracting State" and "an enterprise of the other Contracting State" shall mean an enterprise carried on by a resident of a Contracting State and an enterprise carried on by a resident of the other Contracting State respectively;
  • (h) the term "national" shall mean any individual who under the laws of a Contracting State possesses the nationality of that Contracting State as well as any legal person, general partnership or any other corporation deriving its status as such from the laws in force in a Contracting State;
  • (i) the term "international transport" shall mean any transport by a ship or aircraft operated by an enterprise situated in a Contracting State, except where the effective management of such ship or aircraft is operated solely between places located only in the other contracting State;
  • (j) the term "competent authority" shall mean:
    • (i) For UAE: the Minister of Finance and Industry or his/her legal representative;
    • (ii) For Sudan: the Minister of Finance and National Economy, or his/her legal representative.

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