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ARTICLE 3

General Definitions

(1) For the purpose of this Agreement, unless the context otherwise requires:

  • (a) the terms "a Contracting State " and "the other Contracting State" mean the United Arab Emirates or the Kingdom of Thailand as the context requires;
  • (b) the term " Thailand" means the Kingdom of Thailand and includes any area adjacent to the territorial waters of the Kingdom of Thailand which by Thai legislations and in accordance with the international law has been or may hereafter be designated as an area within which the rights of the Kingdom of Thailand with respect to the seabed and subsoil and their natural resources may be exercised;
  • (c) the term "United Arab Emirates" means the territory of the United Arab Emirates including its territorial waters, islands, airspace, seabed, subsoil and their natural resources over which the United Arab Emirates exercises its sovereign rights in accordance with the United Arab Emirates legislations and the international law.
  • (d) the term "tax" means U.A.E. tax or THAI tax as the context requires;
  • (e) the term "person" includes an individual, a company and any other body of persons as well as any entity treated as a taxable unit under the taxation laws in force in either Contracting State;
  • (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 all individuals possessing the nationality of a Contracting State and all legal persons, partnerships, associations and any other entity deriving their status as such from the laws in force in a Contracting State.

(2) The term "international traffic" means any transport by a ship or aircraft operated by an enterprise of a Contracting State, 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 the United Arab Emirates, the Minister of Finance and Industry or his authorized representative; and
  • (b) in the case of the Kingdom of Thailand, the Minister of Finance or his authorized representative.

(4) In the application of this Agreement by either of the 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.