(1) This Convention shall apply to taxes on income imposed on behalf of a Contracting State, its political subdivisions or its local authorities, irrespective of the manner in which they are levied.
(2) There shall be regarded as taxes on income all taxes imposed on total income or on elements of income, including taxes on gains from the alienation of movable or immovable property, taxes on the total amount of wages paid by enterprises, as well as taxes on capital gains.
(3) The existing taxes to which the Convention shall apply are, in particular:
- (a) In Switzerland:
- (i) federal, cantonal and communal taxes on income (total income, earnings from work, return on assets, business profits, capital gains and other income);
- (hereinafter referred to as "Swiss tax");
- (b) In United Arab Emirates:
- (i) the income tax; and
- (ii) the tax on corporate profits;
- (hereinafter referred to as the "U.A.E. tax").
(4) The Convention shall also apply to any identical or substantially similar taxes which are imposed after the date of signature of this Convention in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify each other of significant changes which have been made in their respective taxation laws.
(5) The Convention shall not apply to taxes withheld at source on gains made in lotteries.