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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 terms "a Contracting State" and "the other Contracting State" mean, depending on the context, the State of Bahrain or the Arab Republic of Syria;
  • (b) the term "Bahrain" means the State of Bahrain and when used in its geographical sense includes its islands, territorial waters, and adjacent areas as well as any other territory situated beyond the limits of the territorial waters of Bahrain, over which Bahrain exercises its sovereign rights with respect to the exploration and exploitation of natural resources from the seabed and its sub-soil, under its domestic and international laws;
  • (c) the term "Syria" means the Arab Republic of Syria and when used in its geographical sense includes the territory of the Arab Republic of Syria, its continental shelf, its subsoil, the air space over them and all other regions situated outside the limits of the territorial waters of Syria, over which Syria exercises its sovereign rights with respect to the exploration and exploitation of natural resources, whether living or non-living, in the sea water, seabed and its subsoil, under its domestic laws and international law;
  • (d) the term "person" includes an individual, a company or any other body of persons;
  • (e) the term "national" means any individual possessing the nationality of that State and any legal person or company deriving its status as such from the laws in force in that Contracting State;
  • (f) the term "company" means any-body corporate or any entity that 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 an enterprise carried on by a resident of a Contracting State and an enterprise carried on by a resident of the other Contracting State, respectively. In this Convention, the term "project", with respect to the Contracting States shall mean "an enterprise";
  • (h) the term "international traffic" means any transport by sea or air operated by an enterprise that has its place of effective management in a Contracting State, except when a ship or aircraft is operated solely between places in the other Contracting State;
  • (i) the term "tax" means the taxes of the State of Bahrain or the taxes of the Arab Republic of Syria, as the case may be;
  • (j) the term "competent authority" means:
    • (i) in the State of Bahrain: the Minister of Finance and National Economy or his authorized representative;
    • (ii) in the Arab Republic of Syria: the Minister of Finance or his authorized representative;
  • (k) the term "fixed base" means the fixed place of business from where independent personal services or any other activities of an independent nature are exercised.

(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 applies and the meaning of any term under the domestic tax laws of the States shall have priority over the meaning of that term under the other laws of the States.