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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) In this Agreement, unless the context otherwise requires:

  • (a) the term "Syria" means the Syrian Arab Republic;
  • (b) the term "Cyprus" means the Republic of Cyprus;
  • (c) the terms "a Contracting State" and "the other Contracting State" mean Syria or Cyprus as the context requires;
  • (d) the term "person" comprises an individual, a company and any other body of persons;
  • (e) the term "company" means any body corporate or any entity which is treated as a body corporate for tax purposes;
  • (f) the term "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 citizenship of a Contracting State;
    • (ii) any legal person, partnership or association deriving its status as such from the law in force in a Contracting State;
  • (h) the term "international traffic" means any transport by a ship or aircraft or road vehicle operated by an enterprise which has its place of effective management in a Contracting State except when the ship or aircraft or road vehicle is operated solely between places in the other Contracting State;
  • (i) the term "competent authority" means:
    • (i) in the case of Syria, the Minister of Finance of the Syrian Arab Republic or his authorised representative;
    • (ii) in the case of Cyprus, the Minister of Finance or his authorised representative.

(2) In the application of this Agreement by a Contracting State, any term not otherwise defined shall, unless the context otherwise requires, have the meaning which it has under the laws of the Contracting State relating to the taxes which are the subject of this Agreement.