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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.

ARTICLE 3

General Definitions

(1) For the purposes of this Convention, unless the context otherwise requires:

  • (a) the term "Syrian Arab Republic SAR" shall mean the region of Syrian Republic, its soil, territorial water, bottom of the land, airspace and any other maritime area subject to the sovereignty of Syria in accordance with the international law;
  • (b) the term "UAE" shall mean the region of UAE which, from the geographic point of view, includes the territorial water, islands, airspace and natural resources on which UAE exercises the sovereign rights; excavations and exploitation of natural resources, in accordance with the international law;
  • (c) the terms "a Contracting State" and "the other Contracting State" shall mean UAE or SAR, as the context requires;
  • (d) the term "tax" shall mean taxes of UAE or SAR, as the context requires, it includes any payments incurred as fines, sanctions or additions to taxes covered by such agreement;
  • (e) the term "person" shall mean any individual, company or any other body of persons, subject to tax legislations in any of the two Contracting States;
  • (f) the term "company" shall mean any corporate body or any entity that is treated as a body corporate for taxation purposes in accordance to the legislations of both countries;
  • (g) the terms "an enterprise of a Contracting State" and "an enterprise of the other Contracting State" shall mean an enterprise, having its headquarters located at a Contracting State and an enterprise, having its headquarters located at the other Contracting State, respectively;
  • (h) the term "national" shall mean:
    • (i) any individual possessing the nationality of a Contracting State;
    • (ii) any body corporate, partnership or association having obtained its status as such from the laws in force in a Contracting State;
  • (i) the term "competent authority" shall mean:
    • (i) In SAR: Minister of Finance or his/her legal representative;
    • (ii) In UAE: Minister of Finance and Industry or his/her legal representative;
  • (j) the term "international traffic" shall mean any transport by a ship or aircraft used by an enterprise situated in a Contracting state, except for ship or aircraft, which is operated solely among places located only at the other Contracting State.

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