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The Agreement between the United Arab Emirates and the Republic of Côte d'Ivoire (Ivory Coast) aims to enhance economic cooperation and eliminate double taxation on income (Preamble). It utilizes the Credit Method for both Contracting States to relieve double taxation (Article 24). Withholding tax is capped at 10% for dividends, interest, royalties, and technical service fees (Articles 10, 11, 12, 13). The Treaty provides a broad definition of Permanent Establishment, including a 6-month threshold for service-related activities (Article 5). It also specifies that government and financial institutions are exempt from tax on dividends, interest, and capital gains (Article 30).

Agreement between the Government of the UNITED ARAB EMIRATES and the Government of the REPUBLIC OF CÔTE D'IVOIRE for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income

StatusIn Force

Signed on24 November 2021

Entered into force14 December 2023

Amended on-

Terminated on-

The Government of the United Arab Emirates and the Government of the Republic of Côte d'Ivoire,

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

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

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 - Interests

Article 12 - Royalties

Article 13 - Fees for Technical Services

Article 14 - Capital Gains

Article 15 - Independent Personal Services

Article 16 - Dependent Personal Services

Article 17 - Directors' Fees

Article 18 - Entertainers and Sportspersons

Article 19 - Pensions, Annuities and Social Payments

Article 20 - Government Service

Article 21 - Students, Trainees, and Apprentices

Article 22 - Teachers and Researchers

Article 23 - Other Income

Article 24 - Elimination of Double Taxation

Article 25 - Non-Discrimination

Article 26 - Mutual Agreement Procedure

Article 27 - Exchange of Information

Article 28 - Members of Diplomatic Missions and Consular Posts

Article 29 - Entitlement to Benefits

Article 30 - Income of Government and Institutions

Article 31 - Miscellaneous Rules

Article 32 - Income from Hydrocarbons

Article 33 - Entry into Force

Article 34 - Termination

Article 1
Persons Covered

The Agreement shall apply to persons who are residents of one or both of contracting States.

Article 1Persons Covered

Article 2Taxes Covered

Article 1
Persons Covered

Article 2
Taxes Covered