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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 Convention, unless the context otherwise requires:

  • (a) the term "Syria" means the Syrian Arab Republic in its geographical sense, which means the territory of the Syrian Arab Republic including its territorial sea, the continental reef, the subsoil, the air space above it and all other areas outside the Syrian territorial sea within which, in accordance with international law and its national legislation, Syria exercises sovereign rights for the purpose of extracting and exploiting the natural, vital and mining resources and all other rights in the water, on land and under the seabed;
  • (b) the term "Italy" means the Italian Republic and includes any area beyond the territorial waters which is designated as an area within which Italy, in compliance with its legislation and in conformity with the international law, exercises sovereign rights in respect of the exploration and exploitation of the natural resources of the seabed, the subsoil and the superjacent waters;
  • (c) the terms "a Contracting State" and "the other Contracting State" mean Syria or Italy, as the context requires;
  • (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 "national" means:
    • (i) any individual possessing the nationality of a Contracting State;
    • (ii) any legal person, partnership and association deriving its status as such from the laws in force in a Contracting State;
  • (i) the term "competent authority" means:
    • (i) in the case of Syria, the Minister of Finance or his authorized representative;
    • (ii) in the case of Italy, the Ministry of Finance.

(2) As regards the application of this Convention by a Contracting State any term not defined therein shall, unless the context otherwise requires, have the meaning which it has under the laws of that Contracting State concerning the taxes to which the Convention applies.