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) For the purposes of this Agreement, unless the context otherwise requires:
- (a) The terms "a Contracting State" and "the other Contracting State" mean the Federal Republic of Germany or the Arab Republic of Egypt, as the context requires, and, if for the purposes of this Agreement used in a geographical sense, the area in which the tax law of the Contracting State concerned is in force, as well as the continental shelf adjacent to the territorial sea, insofar as the Contracting State concerned exercises there in conformity with international law sovereign rights to explore the continental shelf and exploit its natural resources;
- (b) The term "person" means an individual, a company and any other body of persons which is taxed as such;
- (c) The term "company" means anybody corporate or any entity which is treated as a body corporate for tax purposes;
- (d) The terms "resident of a Contracting State" and "resident of the other Contracting State" mean a person who is a resident of the Federal Republic of Germany or a person who is a resident of the Arab Republic of Egypt, as the context requires;
- (e) 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;
- (f) The term "international traffic" means any transport by ship or aircraft operated by an enterprise which has its place of effective management in a Contracting State, except when the ship or aircraft is operated solely between places in the other Contracting State;
- (g) The term "national" means:
- (aa) in respect of the Federal Republic of Germany any German in the meaning of paragraph (1) of Article 116 of the Basic Law for the Federal Republic of Germany and any legal person, partnership and association deriving its status as such from the law in force in the Federal Republic of Germany;
- (bb) in respect of the Arab Republic of Egypt any national of the Arab Republic of Egypt and any legal person, partnership and association deriving its status as such from the law in force in the Arab Republic of Egypt;
- (h) The term "competent authority" means in the case of the Federal Republic of Germany the Federal Ministry of Finance, and in the case of the Arab Republic of Egypt the Minister of Finance or his authorised representative.
(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 the State concerning the taxes to which the Agreement applies.