CONVENTION Between The Government of the STATE OF ISRAEL and the Government of the UNITED ARAB EMIRATES for The Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income

[GTL Notes - See Protocol 1]

The Government of the State of Israel and the Government of the United Arab Emirates

Further to the 'Treaty of Peace, Diplomatic Relations and Full Normalization between the United Arab Emirates and the State of Israel', signed in Washington DC, on 15 September 2020 (hereinafter, 'the Peace Treaty'), and in particular Article 5 thereof, the Agreed Protocol signed in Abu Dhabi on 1 September 2020, and the Mutual Economic Cooperation Memorandum of Understanding between the Ministries of Finance signed in Tel Aviv, on 20 October 2020;

Recalling the agreed principles for cooperation in the sphere of Finance and Investment, which were annexed to the Peace Treaty, and recognizing the high priority of concluding Agreements in the sphere of Finance, and their key role in the Economic Development of both States and the Middle East as a whole;

Intending to conclude a Convention for the elimination of double taxation with respect to the 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: