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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 purpose of this Convention, unless the context otherwise requires:

  • the term "Egypt" means the Arab Republic of Egypt and when used in its geographical sense, the term means:
    • (i) its national territory;
    • (ii) its territorial waters;
    • (iii) its continental shelf; and
    • (iv) the area beyond and adjacent to its territorial waters, over which Egypt, in accordance with international law, exercises its sovereign rights for the purposes of exploration, exploitation and preservation of natural resources, whether living or non-living, in the water, on the seabed, or its subsoil, and any other activity relating to the economic exploitation or exploration of the area and all other rights pertaining to such exploration.

(2) The term "Syria" means the Syrian Arab Republic and when used in its geographical sense, the term means the territory of the Syrian Arab Republic, its continental shelf, its sub-soil, the air space above them and all other regions beyond the territorial waters of Syria, over which the Syrian Arab Republic, in accordance with international law, exercises its sovereign rights relating to the exploration and exploitation of the natural resources, whether living or non-living, in the water, above the seabed and its subsoil.

(3)

  • (a) The terms "a Contracting State" and "the other Contracting State" mean, depending on the context, the Arab Republic of Egypt or the Syrian Arab Republic.
  • (b) The term "person" includes an individual, a company and any other body of persons.
  • (c) The term "company" means anybody corporate or any entity that is treated as a body corporate for the purposes of taxation.
  • (d) The terms "enterprise of a 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.
  • (e) The term "tax" means, depending on the context, Egyptian tax or Syrian tax.
  • (f) 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 where the ship or aircraft is operated solely between places located in the other Contracting State.
  • (g) The term "competent authority" means:
    • (i) in Egypt, the Minister of Finance or his authorized representative;
    • (ii) in Syria, the Minister of Finance or his authorized representative.
  • (h) The term "national" of a Contracting State means:
    • (i) any individual possessing the nationality of that Contracting State; or
    • (ii) any legal person or company deriving its status as such from the laws in force in that Contracting State.