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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 Agreement, unless the context otherwise requires:

  • (a) the term "Croatia" means the territory of the Republic of Croatia as well as those maritime areas adjacent to the outer limit of territorial sea, including seabed and subsoil thereof, over which the Republic of Croatia in accordance with international law (and the laws of the Republic of Croatia) exercises its sovereign rights and jurisdiction;
  • (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, as the context requires, Croatia or Syria;
  • (d) the term "person" includes 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 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;
  • (g) the term "international traffic" means any transport by a ship or aircraft operated by an enterprise which has its place of effective management in a Contracting State, except when the ship or aircraft is operated solely between places in the other Contracting State;
  • (h) the term "competent authority" means:
    • (i) in Croatia, the Minister of Finance or his authorized representative;
    • (ii) in Syria, the Minister of Finance or his authorized representative.
  • (i) 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.

(2) As regards the application of the Agreement at any time by a Contracting State any term not defined therein shall, unless the context otherwise requires, have the meaning that it has at that time under the law of that State for the purposes of the taxes to which the Agreement applies, any meaning under the applicable tax laws of that State prevailing over a meaning given to the term under other laws of that State.