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Singapore - Untd A Emirates Tax Treaty (as amended by 2014 protocol) — Orbitax Tax Hub

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 Agreement, unless the context otherwise requires:

  • *(a) the term "United Arab Emirates" or "U.A.E." means the United Arab Emirates and, 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 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 waters, sea-bed and subsoil for the purposes of exploring and exploiting natural resources by virtue of its law and international law;
  • *(b) the term "Singapore" means the Republic of Singapore and, when used in a geographical sense, includes its land territory, internal waters and territorial sea, as well as any maritime area situated beyond the territorial sea which has been or might in the future be designated under its national law, in accordance with international law, as an area within which Singapore may exercise sovereign rights or jurisdiction with regards to the sea, the sea-bed, the subsoil and the natural resources;
  • (c) the terms "a Contracting State" and "the other Contracting State" mean the United Arab Emirates or Singapore as the context requires;
  • (d) the term "tax" means United Arab Emirates tax or Singapore tax as the context requires;
  • (e) the term "person" includes an individual, a company and any other entity which is treated as a taxable entity under the tax laws of the respective Contracting States;
  • (f) the term "company" means any body corporate or any entity which 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 "national" means:
    • (i) in the case of United Arab Emirates, all individuals possessing the nationality of United Arab Emirates in accordance with United Arab Emirates laws and any legal person, partnership and other body corporate deriving the status as such from United Arab Emirates laws;
    • (ii) in relation to Singapore, any individual possessing the citizenship of Singapore, and any legal person, partnership, association and any other entity deriving its status as such from the laws in force in Singapore;
  • (i) the terms "resident of a Contracting State" and "resident of the other Contracting State" mean a person who is a resident of United Arab Emirates or a person who is a resident of Singapore as the context requires.

(2) The term "international traffic" means any transport by ships or aircraft operated by an enterprise which has its place of management in either of the Contracting States except when the ship or aircraft is operated solely between places in the other Contracting State.

(3) The term "competent authority" means:

  • (a) in the case of United Arab Emirates, the Minister of Finance and Industry or his authorised representative; and
  • (b) in the case of Singapore, the Minister for Finance or his authorised representative.

(4) In the application of the 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 the Agreement applies.