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Covering income and capital, this agreement applies to Ukraine's enterprise profit tax and personal income tax, and UAE's income and corporation tax. The treaty sets tiered withholding tax rates: 5% on dividends for companies with at least a 10% holding (15% otherwise) and 5% on interest. Royalties are taxed at 10% for literary/artistic works and 5% for scientific works, patents, and trademarks. A specific article (29B) preserves domestic laws for taxing hydrocarbon income. Double taxation is eliminated through the tax credit method for residents of both states, as outlined in Article 25.

Agreement between the Government of UKRAINE 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 and Capital

StatusIn Force

Signed on22 January 2003

Entered into force9 March 2004

Amended on-

Terminated on-

The Government of Ukraine and the Government of the United Arab Emirates, Desiring to further develop their economic relationship and to enhance their cooperation in tax matters, Intending to eliminate double taxation with respect to taxes covered by this Agreement 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 Agreement for the indirect benefit of residents of third States),

Have agreed as follows:

Contents

Article 1 - Personal Scope

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 - Shipping and Air Transport

Article 9 - Associated Enterprises

Article 10 - Dividends

Article 11 - Interest

Article 12 - Royalties

Article 13 - Capital Gains

Article 14 - Independent Personal Services

Article 15 - Dependent Personal Services

Article 16 - Teachers and Researchers

Article 17 - Students and Trainees

Article 18 - Directors' Fees

Article 19 - Pensions and Annuities

Article 20 - Government Services

Article 21 - Artists and Sportsmen

Article 22 - Other Income

Article 23 - Capital

Article 24 - Special Provision

Article 25 - Methods of Elimination of Double Taxation

Article 26 - Non-discrimination

Article 27 - Mutual Agreement Procedure

Article 28 - Exchange of Information

Article 29 - Members of Diplomatic Missions and Consular Posts

Article 29A - Entitlement to Benefits

Article 29B - Income from Hydrocarbons

Article 30 - Entry into Force

Article 31 - Termination

Protocol

Article 1
Personal Scope

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

Article 1Personal Scope

Article 2Taxes Covered

Article 1
Personal Scope

Article 2
Taxes Covered