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June 26, 2026

The UAE-Brazil DTAA on income sets withholding tax rates as follows: dividends at 5% for government entities (15% otherwise); interest at 10% for specific long-term bank loans (15% otherwise); and 15% for both royalties and fees for technical services. The treaty contains an Entitlement to Benefits" clause to prevent abuse and allows domestic law for natural resources taxation. A construction site creates a permanent establishment if it lasts more than six months. To eliminate double taxation, both states apply the credit method."

Convention between the FEDERATIVE REPUBLIC OF BRAZIL and THE UNITED ARAB EMIRATES for the Elimination of Double Taxation with respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance

[GTL Notes - See Protocol]

StatusIn Force

Signed on10 November 2018

Entered into force15 March 2021

Amended on-

Terminated on-

Desiring to further develop their economic relationship and to enhance their cooperation in tax matters,

Intending to conclude a Convention for the elimination of double taxation with respect to taxes on income without creating opportunities for non-taxation or reduced taxation through tax evasion or avoidance (including through treaty-shopping arrangements aimed at obtaining reliefs provided in this Convention for the indirect benefit of residents of third States),

Have agreed as follows:

Contents

Article 1 - Persons Covered

Article 2 - Taxes Covered

Article 3 - General Definitions

Article 4 - Resident

Article 5 - Permanent Establishment

Article 6 - Income from Immovable Property

Article 7 - Business Profits

Article 8 - International Shipping and Air Transport

Article 9 - Associated Enterprises

Article 10 - Dividends

Article 11 - Interest

Article 12 - Royalties

Article 13 - Fees for Technical Services

Article 14 - Capital Gains

Article 15 - Independent Personal Services

Article 16 - Income from Employment

Article 17 - Directors' Fees

Article 18 - Entertainers and Sportspersons

Article 19 - Pensions

Article 20 - Government Service

Article 21 - Teachers and Researchers

Article 22 - Students

Article 23 - Natural Resources

Article 24 - Other Income

Article 25 - Elimination of Double Taxation

Article 26 - Non-discrimination

Article 27 - Mutual Agreement Procedure

Article 28 - Exchange of Information

Article 29 - Entitlement to Benefits

Article 30 - Members of Diplomatic Missions and Consular Posts

Article 31 - Entry into Force

Article 32 - Termination

Protocol

Article 1
Persons Covered

At the moment of the signature of the Convention between the Federative Republic of Brazil and the United Arab Emirates for the Elimination of Double Taxation with Respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance, the undersigned, duly authorised thereto, have agreed upon the following provisions which constitute an integral part of the Convention.

This is an unofficial / best effort translation

Article 1Persons Covered

Article 1
Persons Covered