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June 26, 2026

This agreement covers taxes on income and includes a specific article allowing the UAE to apply its domestic law to income from hydrocarbons. It sets fixed withholding tax rates on cross-border payments: 15% on dividends, 10% on interest, and 10% on royalties. The convention contains standard articles for taxing business profits and profits from ship and aircraft operations. To prevent double taxation, both the UAE and New Zealand apply the credit method. It also includes standard non-discrimination, mutual agreement procedure, and exchange of information clauses, with an integral Protocol clarifying specific implementations and definitions.

Agreement between the Government of NEW ZEALAND 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 9 & 10]

StatusIn Force

Signed on22 September 2003

Entered into force29 July 2004

Amended on-

Terminated on-

The Government of New Zealand and the Government of the United Arab Emirates,

Desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income,

Have agreed as follows:

Contents

Article 1 - Persons Covered

Article 2 - Taxes Covered

Article 3 - Income from Hydrocarbons

Article 4 - General Definitions

Article 5 - Residence

Article 6 - Permanent Establishment

Article 7 - Income from Immovable Property

Article 8 - Business Profits

Article 9 - Ship and Aircraft Operations

Article 10 - Associated Enterprises

Article 11 - Dividends

Article 12 - Interest

Article 13 - Royalties

Article 14 - Alienation of Property

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 - Students

Article 22 - Other Income

Article 23 - Elimination of Double Taxation

Article 24 - Mutual Agreement Procedure

Article 25 - Exchange of Information

Article 26 - Members of Diplomatic Missions and Consular Posts

Article 27 - Entry into Force

Article 28 - Termination

Protocol

Article 1
Persons Covered

This Agreement shall apply to persons who are residents of one or both of the Contracting States.

Article 2
Taxes Covered

The existing taxes to which this Agreement shall apply are:
1. In the United Arab Emirates: the income tax and the corporation tax; (hereinafter referred to as 'United Arab Emirates Taxes');
2. In New Zealand: the income tax; (hereinafter referred to as 'New Zealand Taxes').
The Agreement shall apply also to any identical or substantially similar taxes that are imposed after the date of signature of the Agreement in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify each other within a reasonable period of time of any significant changes that have been made in their taxation laws.
Notwithstanding the provisions of paragraphs 1 and 2, the taxes covered by the Agreement do not include any amount which represents a penalty or interest imposed under the laws of either Contracting State.

Article 1Persons Covered

Article 2Taxes Covered

Article 1
Persons Covered

Article 2
Taxes Covered