Beta Version

Website Last updated:

June 26, 2026

The Convention between the United Arab Emirates and the Democratic Republic of Congo seeks to eliminate double taxation and prevent fiscal evasion (Preamble). It covers income taxes and capital appreciation (Article 2). Double taxation relief is provided through the Exemption Method for most income, with the Credit Method applied specifically to dividends, interest, and royalties (Article 25). The Treaty establishes withholding tax caps of 5% for royalties and technical service fees (Articles 13, 14). It also includes a Principal Purpose Test (Article 29) to prevent treaty shopping and specifies rules for income from hydrocarbons and mining (Article 3).

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

StatusIn Force

Signed on12 October 2021

Entered into force24 January 2023

Amended on-

Terminated on-

Preamble

The Government of the United Arab Emirates and the Government of the Democratic Republic of Congo,

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 benefits of residents of third States),

Have agreed as follows:

Contents

Article 1 - Persons Covered

Article 2 - Taxes Covered

Article 3 - Income from Hydrocarbons and Mining

Article 4 - General Definitions

Article 5 - Resident

Article 6 - Permanent Establishment

Article 7 - Income from Immovable Property

Article 8 - Business Profits

Article 9 - International Shipping and Air Transport

Article 10 - Associated Enterprises

Article 11 - Dividends

Article 12 - Interest

Article 13 - Royalties

Article 14 - Fees for Technical Services

Article 15 - Capital Gains

Article 16 - Independent Personal Services

Article 17 - Dependent Personal Services

Article 18 - Directors' Fees

Article 19 - Entertainers and Sportspersons

Article 20 - Pensions and Annuities

Article 21 - Government Service

Article 22 - Students and Business Apprentice

Article 23 - Professors and Researchers

Article 24 - Other Income

Article 25 - Elimination of Double Taxation

Article 26 - Mutual Convention Procedure

Article 27 - Exchange of Information

Article 28 - Members of Diplomatic Missions and Consular Posts

Article 29 - Entitlement to Benefits

Article 30 - Miscellaneous Rules

Article 31 - Income of Government and Institutions

Article 32 - Entry into Force

Article 33 - Termination

Article 1Persons Covered

Article 1
Persons Covered