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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 term "Contracting State" means Armenia or Syria as the context requires;
  • (b) the term "Armenia" means the Republic of Armenia;
  • (c) the term "Syria" means, in accordance with international law, the territories of the Syrian Arab Republic including its internal waters, territorial sea, the subsoil thereof and the airspace above them to which Syria has sovereign rights and other maritime areas to which Syria has the right to exercise sovereign rights for the purposes of exploration, exploitation and conservation of natural sources;
  • (d) the term "person" includes an individual, a company and any other body of persons;
  • (e) the term "company" means anybody corporate, or any entity which is treated as a body corporate for tax purposes;
  • (f) 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;
  • (g) the term "national" means:
    • (i) any individual possessing the nationality of a Contracting State;
    • (ii) any legal person, deriving its status as such from the laws in force in a Contracting State;
  • (h) the term "international traffic" means any transport by a ship, boat, aircraft, or road vehicle operated by an enterprise of a Contracting State, except when such transport is operated solely between places in the other Contracting State;
  • (i) the term "competent authority" means:
    • (i) in the case of Armenia: the Minister of Finance and Economy or his authorized representative and the Head of State Tax Service or his authorized representative;
    • (ii) in the case of Syria: the Minister of Finance or his authorized representative.

(2) As regards the application of the Convention at any time by a Contracting State any term not defined therein shall, unless the context otherwise requires or the competent authorities of the Contracting States are not able to reach a mutual opinion according to the procedure mentioned in Article 25 of this Convention, have the meaning which it has at that time under the law of that State concerning the taxes to which the Convention applies.