In application of the provisions of this Resolution, the following words and phrases shall have the meanings assigned to each, unless the context indicates otherwise:
State: The United Arab Emirates.
Banking Operations: Shall have the meaning specified by the Law regulating these operations in the State.
Working Day: Days of the week from Sunday to Thursday, except official holidays.
Document: Any document that:
    a. Relates to the exercise of a relevant activity by the licensee or the excluded licensee.
    b. Forms a part of any register pursuant to any legislation applicable to a licensee or an excluded licensee.
Work Headquarters: The headquarters used to exercise any business relevant to the State by a licensee or an excluded licensee.
Competent Authority: Ministry of Finance.
The Central Bank: Central Bank of the United Arab Emirates.
Competent Foreign Authority: The foreign authority relevant to an international agreement, convention or any similar arrangement made by the State to demand and receive any information or documents relevant to the enforcement of any provisions stipulated in this Resolution.
Relevant Person: An entity forms a part of the same group to which the licensee or excluded licensee belongs.
Distribution and Service Provision Centre: A Centre engages in any of the two following activities:
    a. Purchasing spare parts, goods material or goods that are ready for sale from a relevant foreign person and reselling such spare parts or goods.
    b. Providing services to relevant foreign persons.
Requirements of Real Economic Activities: Requirements specified in Article (6) of this Resolution.
Requirements of Real Economic Activities Report: Report to be submitted pursuant to provision of Clause (4) of Article (8) and in accordance with provision of Clause (5) of Article (8) of this Resolution.
Financial Free Zone: A financial free zone incorporated subject to the aforementioned Federal Law No. (8) of 2004.
Financial Free Zone Authority: The authority authorized in the relevant financial free zone, for purposes of this Resolution, to be the Regulatory Authority.
Fiscal Year: The fiscal year of commercial businesses of a licensee or an excluded licensee.
Relevant Foreign Person: Relevant person whose tax residence is not in the State.
Free Zone: A free zone established in the State.
Free Zone Authority: The authority authorized in the relevant free zone, for purposes of this Resolution, to be the Regulatory Authority.
Operations of Investment Funds Management: Shall have the meaning specified by the Law regulating these operations in the State.
Operations of the Headquarters: Provision of any of the following services to a relevant foreign person/persons:
    a. Duties of Senior Management
    b. To basically handle or control risks related to activities exercised by the relevant foreign person or risks related to assets owned by such relevant foreign person.
    c. Giving advice concerning subjective decisions to handle or control risks referred to in Paragraph (B) of this definition.
Licensee Exercising "High Risks" Intellectual Property Activity: The person licensed to exercise intellectual property works which:
    a. He did not create ownership right on the assets of intellectual property under his hand by himself for the purposes of doing commercial businesses.
    b. Intellectual property assets are owned:
        1. From a relevant person.
        2. (2) For financing the research and development processes conducted by a person residing in a country other than the State.
    c. He shall license or sell the intellectual property assets to relevant person/persons or, otherwise, shall get a verifiable income from a relevant foreign person, with regard to use or exploitation of such assets.
Holding Company Operations: Shall mean the activity which:
    a. Its function is limited to owning and possessing shares or securities or rights in other companies.
    b.  Its income comes from the capital profits and returns from the capital rights.
The Income Arising from The Intellectual Property Rights: Shall include any of the following:
    a. The revenues
    b. An income from a concession contract.
    c. The income arising from licensing the intellectual property rights
    d. The income accrued from value increase or any other income arising from selling the intellectual property assets.
Insurance Operations: Shall have the meaning specified by the Law regulating these operations in the State.
Intellectual Property Operations: Operations of owning, using or receiving income from intellectual property assets.
Intellectual Property Assets: Any right of intellectual property in intangible assets, including without limitation, copyrights, patents, trademarks, commercial feature and technological knowledge from which an income is accrued that can be separated in accounts from any revenues accrued from any tangible assets.
Notice: Notice that should be submitted pursuant to provisions of Article (8) of this Resolution.
Finance Leasing Operations: Shall have the meaning specified by the Law regulating these operations in the State.
National Authority for Evaluation: Federal Tax Authority entrusted in accordance with provisions of Article (5) of this Resolution.
Regulatory Authority: Authority or authorities entrusted to regulate any activity related to purposes of this Resolution, as specified in Article (4) of this Resolution.
Relevant Activity: Any of the activities stipulated in Article (3) of this Resolution.
License: Commercial license or permission issued by the competent licensing authority in State including, free zone and financial free zone.
Licensee: Any of the two following entities:
    a. Legal person (incorporated inside or outside state).
    b. Joint coalition that does not have the independent legal personality.
It shall be registered in State, including the free zone and financial free zone, and shall carry out a relevant activity.
Excluded Licensee: Any of the following licensees:
    a. Investment Fund.
    b. Licensee which its tax headquarters is outside State.
    c. Licensee that is fully owned by one or more residents in State and meets the two following requirements:
        1. It shall not be a part of a MNE Group.
        2. It shall carry out its activity in State only.
    d. Branch of a foreign entity registered in State that its income from the relevant activity is subject to tax in any other country except the State.
    e. Any licensee for which a resolution is issued by Minister of Finance to be granted the capacity of "Excluded Licensee".
Beneficiary from Capital Ownership: The natural person directly or indirectly owns twenty five percent (25%) or more of capital shares of licensee or excluded licensee.
Vessel: Shall have the same meaning stipulated in Article 11 of Federal Law No. 26 of 1981 on Maritime Commercial Law, as amended. However, this shall not include a fishing vessel, small vessel or cruising boat (as stipulated in Article 18 of the same law).
Consolidated Financial Statements: Consolidated Financial Statements for the Group which include all assets, liabilities, income, expenses and financial flows of the parent company in money as a single economic unit.
Group: Two or more entities interconnected through an ownership or a control to the extent that it shall prepare consolidated financial statements, according to the accounting standard applicable thereto, for submitting the financial reports.
Investment Fund: An entity which its main activity is to issue investment rights to collect funds or collect the funds of investors to enable the owner of the investment right to benefit from the profits or revenue arising when such entity acquires, gets or manages the disposition of investments. This shall include any entity through which the investment fund has directly or indirectly invested. This definition shall not include the entity or group of entities in which the fund invests.
MNE Group: Any group consists of any of the following:
    1. Two or more entities which the tax residence of each locates in different countries.
    2. One entity resides in a country for tax purposes and is subject to a tax for the activities it carries out through a branch or a permanent establishment in another country.
Joint Coalition: a. Limited Partnership (which does not have an independent legal personality).
b. General Partnership Company. It is registered in State including, free zone or financial free zone.
Income Arising from Relevant Activity: Total income arising from a relevant activity and is registered in the records of licensee or excluded licensee according to the applicable accounting standards.
Shipping Operations: The activity involves the operation of a vessel anywhere in the world, other than the territorial waters of State, including:
    a. Operations of transport of passengers, animals, goods or mails by sea.
    b. Chartering a vessel for a voyage or for certain period for the purpose indicated in Paragraph (A) above.
    c. Selling travel tickets or equivalent and additional services relating to the operation of the vessel.
    d. Usage, maintenance or leasing of containers, including trailers and other vehicles or equipment necessary for containers carrying used to transport anything by sea.
    e. Managing the vessel crew.
The Activity Generates a Main Income: Shall have the meaning stipulated in Article (3) of this Resolution.
Parent Company: The entity that:
    a. Is directly owned to the right to voting by majority in the licensee or excluded licensee.
    b. Has the right to appoint or dismiss the majority of members of board of directors of the licensee or excluded licensee.
    c. Dominates, solely or under a mutual arrangement with shareholders or other members, the right of voting by majority in the licensee or excluded licensee.
    d. Has the right to initiate, or effectively initiates, the power of affecting or direct control in the licensee or excluded licensee.
Ultimate Parent Company: The entity member to the group that has the following standards:
    a. It shall directly or indirectly own in the licensee or excluded licensee an interest sufficient to be required to prepare consolidated financial statements according to the accounting standards applicable thereto, or this would have been requested therefrom if the ownership rights therein are tradeable in a securities market in its tax residence country.
    b. No other member to the group shall directly or indirectly own an interest therein requiring it to prepare consolidated financial statements according to the accounting standards applicable thereto, or this would have been requested therefrom if the ownership rights therein are tradeable in a securities market in its tax residence country.
Third-Party Service Provider: A person or entity exercising an activity generating a main income on behalf of the licensee, in accordance with the conditions stipulated in Clause (2) of Article (6) of this Resolution.