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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, as per the context, Algeria or Syria;
  • (b) the term "Algeria" means the People's Democratic Republic of Algeria and, used in a geographical sense, it means the territory of the People's Democratic Republic of Algeria, including the territorial sea and beyond thereof, the areas on which, in accordance with international law and domestic laws, the People's Democratic Republic of Algeria exercises its jurisdiction or sovereign rights for exploration and exploitation of natural resources of the seabed, the subsea bottom and the water column situated on top thereof;
  • (c) the term "Syria" means, in its geographical sense, the territory of the Syrian Arab Republic, including the territorial sea, airspace, continental soil, the subsoil and all other areas situated beyond the Syrian territorial sea over which Syria exercises its sovereign rights under international law for the purposes of the exploration and exploitation of mineral, organic, natural resources, and all other rights on the seabed, the subsea bottom and the water column situated on top thereof;
  • (d) the term "person" includes individuals, companies and any other body of persons;
  • (e) the term "national" means:
    • (1) any individual possessing the nationality of a Contracting State;
    • (2) any body corporate and partnership or legal institution established under 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 whose place of effective management is situated in a Contracting State, except when the ship or aircraft is only operated between points in the other Contracting State;
  • (i) the term "competent authority" means:
    • (1) With respect to Algeria, the Minister of Finance or his authorized representative;
    • (2) With respect to Syria, the Minister of Finance or his representative.

(2) For the purposes of the application of the Convention by a Contracting State, any term not defined therein shall have the meaning which it has under the law of that State relating to the taxes covered by the Convention, and this means that such law shall prevail over the meaning given to that term by another branch of the law of that State.