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Vietnam - Morocco Tax Treaty (2008) — Orbitax Tax Hub
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 terms "a Contracting State" and " the other Contracting State" mean Vietnam or Morocco, as the context requires;
  • (b) the term "Vietnam" means the Socialist Republic of Vietnam, when used in a geographical sense, it means all its national territory, including its territorial sea and any area beyond and adjacent to its territorial sea, within which Vietnam by Vietnamese legislation and in accordance with international law, has sovereign rights of exploration for and exploitation of natural resources of the seabed and its sub-soil and superjacent watermass;
  • (c) the term "Morocco" means the Kingdom of Morocco and, when used in a geographical sense, the term "Morocco" includes:
    • (i) the territory of the Kingdom of Morocco, the territorial sea thereof; and
    • (ii) the maritime areas beyond the territorial sea, including the seabed and subsoil thereof (continental shelf) and the exclusive economic zone over which Morocco exercises sovereign rights, in accordance with its domestic laws and international law, for the purposes of exploration and exploitation of the natural resources of such areas;
  • (d) the term "tax" means Vietnamese tax or Moroccan tax, as the context requires;
  • (e) the term "person" includes an individual, a company, a partnership and any other body of persons;
  • (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 that has its place of effective management (e.g. head office) in a Contracting State, except when the ship or aircraft is operated solely between places in the other Contracting State;
  • (i) the term "competent authority" means:
    • (i) in the case of Vietnam, the Minister of Finance or his authorized representative;
    • (ii) in the case of Morocco, the Minister of Finance or his authorized representative;
  • (j) 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.