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PROTOCOL

At the time of signing the Agreement between the United Arab Emirates and the Republic of Angola for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income, the undersigned have agreed that the following shall form an integral part of the Agreement:

With respect to Articles 7, 11, 12, 14 paragraph (4) of Article 15 and paragraph (5) of Article 17, it is understood that the entities listed below qualify as government entities, and their income and gains shall be taxable only in the Contracting State where they are resident:

  • (a) In the case of the United Arab Emirates:
    • (1) Central Bank of the United Arab Emirates;
    • (2) Abu Dhabi Investment Authority;
    • (3) Abu Dhabi Investment Council;
    • (4) Emirates Investment Authority;
    • (5) Mubadala Investment Company;
    • (6) Mubadala Development Company and its successors and assigns;
    • (7) International Petroleum Investment Company (IPIC) and its successors and assigns;
    • (8) Dubai World;
    • (9) Investment Corporation of Dubai;
    • (10) Abu Dhabi National Energy Company (TAQA)
    • (11) the Abu Dhabi Retirement Pensions and Benefits Fund;
    • (12) the General Pension and Social Security Authority; and
  • any other entity the capital of which is directly or indirectly wholly owned by the federal or local Governments of the United Arab Emirates, including a political subdivision and local authority thereof through notifications by the competent authorities through diplomatic channels.
  • (b) In case of the Republic of Angola:
    • (1) Angola Sovereign Fund;
    • (2) Sonangol;
    • (3) The Government Pension Fund (INSS), and

any other entity the capital of which is directly or indirectly wholly owned by the federal or local Governments of the Republic of Angola, including a political subdivision and local authority thereof through notifications by the competent authorities through diplomatic channels.

IN WITNESS WHEREOF, the undersigned, duly authorized thereto by their respective Governments, have signed this Protocol.

DONE at Luanda on 8 February 2018, in two originals Arabic, Portuguese and the English language. In case if divergence between the texts the English text shall prevail.

FOR THE GOVERNMENT OF THE UNITED ARAB EMIRATES:

FOR THE GOVERNMENT OF THE REPUBLIC OF ANGOLA: