Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.
ARTICLE 23
Elimination of Double Taxation
(1) In the United Arab Emirates, double taxation shall be avoided as follows:
- (a) Where a resident of the United Arab Emirates derives income from Ecuador which, in accordance with the provisions of this Agreement, may be taxed in Ecuador, the United Arab Emirates shall allow as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in Ecuador.
- Such deduction shall not, however, exceed that part of the income tax, as computed before the deduction is given, which is attributable to the income, which may be taxed in Ecuador.
- (b) Where in accordance with any provision of this Agreement income derived by a resident of the United Arab Emirates is exempt from tax in that State, such State may nevertheless, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income.
(2) In Ecuador, double taxation shall be avoided as follows:
- (a) Where a resident of Ecuador derives income which, in accordance with the provisions of this Agreement, may be taxed in the United Arab Emirates, Ecuador shall, subject to the provisions of subparagraphs b) and c), exempt such income from tax.
- (b) Where a resident of Ecuador derives items of income which, in accordance with the provisions of articles 11, 12 and 13, may be taxed in the United Arab Emirates, Ecuador shall allow as a deduction from the tax on the income of that resident an amount equal to the tax paid in the United Arab Emirates. Such deduction shall not, however, exceed that part of the tax, as computed before the deduction is given, which is attributable to such items of income derived from the United Arab Emirates.
- (c) Where in accordance with any provision of this Agreement income derived by a resident of Ecuador is exempt from tax in that State, such State may nevertheless, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income.
- (d) The provisions of subparagraph a) shall not apply to income derived by a resident of Ecuador where the United Arab Emirates applies the provisions of this Agreement to exempt such income from tax or applies the provisions of paragraph 2 of Article 11, 12 or 13 to such income.