TREATY: United Arab Emirates – Venezuela\n\nPART A — TAX RATES\n Dividends: 0% / 5% / 10%: 0% for government entities; 5% where recipient is a company holding directly ≥10% of capital; 10% in all other cases [Art. 11]\n Interest: 0% / 10%: 0% for government entities; 10% in all other cases [Art. 12]\n Royalties: 10% [Art. 13]\n FTS: 10% [Art. 13]\n CG – Immovable Property: May be taxed in source state [Art. 14]\n CG – Shares: Source state may tax: shares principally from immovable property, or shares representing ≥50% participation / Residence state only: all other shares [Art. 14]\n Construction PE: 6 months [Art. 6]\n Services PE: Not provided [N/A]\n\nPART B — SPECIAL PROVISIONS\n• Hydrocarbons carve-out — preserves the right of each state to apply its domestic laws regarding the taxation of income and profits derived from hydrocarbons and associated activities [Art. 3]\n• Participation exemption (dividends) — reduces the dividend rate to 5% where the recipient is a company holding directly at least 10% of the paying company's capital [Art. 11]\n• Government / sovereign income exemption — exempts from source taxation dividends and interest paid to the government, central bank, and specifically listed state-owned entities such as ADIA and Mubadala [Arts. 11, 12]\n• Make available / FTS rule — subjects fees for technical assistance to source taxation only when the services make technical knowledge, experience, skills, know-how, or processes available to the recipient [Art. 13]\n• Participation exemption (capital gains on shares) — allows the source state to tax capital gains on the alienation of shares representing a participation of at least 50% in a resident company [Art. 14]