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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 Agreement, unless the context otherwise requires:

  • (a) the term "China" means the People's Republic of China; when used in geographical sense, means all the territory of the People's Republic of China, in which the Chinese laws relating to taxation apply, including its territorial sea, and any area beyond its territorial sea, within which the People's Republic of China has sovereign rights for the purpose of exploring and exploiting the resources of the seabed and its subsoil and superjacent water in accordance with international law and its domestic law;
  • (b) 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 resources;
  • (c) the terms "a Contracting State" and "the other Contracting State" mean China or Syria, as the context requires;
  • (d) the term "person" includes an individual, a company and any other body of persons;
  • (e) the term "national" means:
    • (i) any individual possessing the nationality of a Contracting State;
    • (ii) any legal person, partnership or association deriving its status as such from the laws in force in a 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 "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;
  • (i) the term "competent authority" means:
    • (i) in the case of China, the State Administration of Taxation or its authorized representative;
    • (ii) in the case of Syria, the Minister of Finance or his authorized 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 at that time under the law of that State concerning the taxes to which this Agreement applies.