1. For the purposes of this Convention, unless the context otherwise requires:
(a) the term “United Arab Emirates” means the United Arab Emirates and, when used in a geographical sense, means the territory of the mainland and islands under its sovereignty including the territorial sea and airspace, as well as the sea bed and subsoil over which in accordance with international law the United Arab Emirates exercises, under the law of the United Arab Emirates, sovereign rights with respect to the exploration and exploitation of the natural resources thereof;
(b) the term “United Kingdom” means Great Britain and Northern Ireland and, when used in a geographical sense, means the territory and territorial sea of Great Britain and Northern Ireland and the areas beyond that territorial sea over which Great Britain and Northern Ireland exercise sovereign rights or jurisdiction in accordance with their domestic law and international law;
(c) the term “business” includes the performance of professional services and of other activities of an independent character;
(d) the term “company” means any body corporate or any entity that is treated as a body corporate for tax purposes;
(e) the term “competent authority” means:
(i) in the case of the United Arab Emirates, the Minister of Finance or his authorised representative;
(ii) in the case of the United Kingdom, the Commissioners for Her Majesty’s Revenue and Customs or their authorised representative;
(f) the terms “a Contracting State” and “the other Contracting State” mean the United Arab Emirates or the United Kingdom, as the context requires;
(g) the term “enterprise” applies to the carrying on of any business;
(h) 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;
(i) the term “international traffic” means any transport by a ship or aircraft, except when the ship or aircraft is operated solely between places in a Contracting State and the enterprise that operates the ship or aircraft is not an enterprise of that State;
(j) the term “national” means:
(i) in respect of the United Arab Emirates:
aa) any individual possessing the nationality of the United Arab Emirates;
bb) any legal person, partnership or association deriving its status as such from the laws in force in the United Arab Emirates;
(ii) in relation to the United Kingdom, any British citizen, or any British subject not possessing the citizenship of any other Commonwealth country or territory, provided he has the right of abode in the United Kingdom; and any legal person, partnership or association deriving its status as such from the laws in force in the United Kingdom;
(k) the term “pension scheme” means any scheme or other arrangement which:
(i) is generally exempt from income taxation; and
(ii) operates to administer or provide pension or retirement benefits or to earn income for the benefit of one or more such arrangements;
(l) the term “person” includes an individual, a company and any other body of persons;
(m) the term “recognised stock exchange” means:
(i) the Abu Dhabi Securities Exchange, the Dubai Financial Market, the Abu Dhabi Global Market, the Dubai Gold and Commodities Exchange, any successors thereto, and any other United Arab Emirates investment exchange recognised under United Arab Emirates law;
(ii) the London Stock Exchange, any successor thereto and any other United Kingdom investment exchange recognised under United Kingdom law; and
(iii) any other stock exchange agreed upon by the competent authorities.
2. As regards the application of the Convention 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 this Convention 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.