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This Protocol amends the Double Taxation Avoidance Agreement between the UAE and Luxembourg. It significantly revises Article 13 (Capital Gains), stipulating that gains from shares listed on a recognized securities market in one state are taxable only in the other state, while gains from unlisted shares remain taxable in the alienator's residence state. Article 23 is updated to grant Luxembourg residents exemptions on income derived from UAE permanent establishments in specific sectors (agriculture, industry, infrastructure, tourism). Additionally, it replaces Article 26 to align Exchange of Information with OECD standards and updates the list of government entities qualifying for dividend exemptions.

Protocol to Amend the Convention between the UNITED ARAB EMIRATES and the GRAND DUCHY OF LUXEMBOURG for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital, and the Protocol, Signed at Dubai on 20 November 2005

The Government of the United Arab Emirates and the Government of the Grand Duchy of Luxembourg

Desiring to conclude a Protocol to amend the Convention between the United Arab Emirates and the Grand Duchy of Luxembourg for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital, and the Protocol, signed at Dubai on 20 November 2005, (hereinafter referred to as "the Convention"), have agreed as follows:

Contents

Article 1

Article 2

Article 3

Article 4

Article 5

Article 6

Article 1

Paragraph 4 of Article 13 (CAPITAL GAINS) of the Convention shall be deleted and replaced by the following:

"4. Gains derived from the alienation of shares, bonds and any other securities or similar instruments, listed on a recognized securities market of a Contracting State shall be taxable only in the other Contracting State."

A new paragraph 5 shall be added to Article 13 (CAPITAL GAINS) of the Convention:

"5. Gains derived from the alienation of shares in a company other than those referred to in paragraphs 1 to 4 such as securities, bonds, debentures and the like, shall be taxable only in the State of which the alienator is a resident."

Article 2

Paragraph 1 of Article 23 (ELIMINATION OF DOUBLE TAXATION) of the Convention shall be deleted and replaced by the following:

"1. Subject to the provisions of the law of Luxembourg regarding the elimination of double taxation which shall not affect the general principle hereof, double taxation shall be eliminated as follows: