PROTOCOL TO THE AGREEMENT BETWEEN THE GOVERNMENT OF THE UNITED ARAB EMIRATES AND THE GOVERNMENT OF HIS MAJESTY THE SULTAN AND YANG DI-PERTUAN OF BRUNEI DARUSSALAM FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL
On signing of the Agreement between the Government of the United Arab Emirates and the Government of His Majesty the Sultan and Yang Di-Pertuan of Brunei Darussalam for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital (hereinafter referred to as the "Agreement"), the undersigned have agreed upon the following provisions of this Protocol which shall form an integral part of the Agreement.
- (1) Any income and profits excluding income and profits from hydrocarbons and other natural resources, derived by a Contracting State, its political subdivisions, local governments, statutory bodies, their financial institutions and wholly owned subsidiary companies arising in the other Contracting State, including gains from the alienation of movable and immovable property situated in that other Contracting State, shall be exempt from taxes on such income, profits and gains liable in that other Contracting State.
- (2) Nothing in this Agreement shall affect the right of either one of the Contracting States, or of any of their local governments or local authorities thereof to apply their domestic laws and regulation related to the taxation of income and profits derived from hydrocarbons and its associated activities and other natural resources situated in the territory of the respective Contracting State, as the case may be.
IN WITNESS WHEREOF, the undersigned, duly authorised by their respective Governments, have signed this Protocol.
DONE in duplicate at Dushanbe on this 21 day of May 2013 in the Malay, Arabic and English languages, all text being equally authentic. In case of any divergence, the English text shall prevail.
FOR THE GOVERNMENT THE UNITED ARAB EMIRATES:
HIS EXCELLENCY OBAID HUMAID AL TAYER
MINISTER OF STATE FOR FINANCIAL AFFAIRS
FOR THE GOVERNMENT OF HIS MAJESTY THE SULTAN AND YANG DI-PERTUAN OF BRUNEI DARUSSALAM:
THE HONOURABLE PEHIN DATO ABD RAHMAN IBRAHIM
MINISTER OF FINANCE II AT THE PRIME MINISTER'S OFFICE