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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.

PROTOCOL

At the time of signing on this convention between the government of United Arab Emirates and the government of Egypt to eliminate evasion of income tax, the undersigned have agreed that the following provisions shall form an integral part of the convention:

(1) With reference to the whole convention:

It is understood that the convention shall not limit by any means any concession (such as exclusion, exemption, tax reduction, deduction, tax discount or other allowances) granted now or later:

  • (a) By virtue of the laws of any of the two contracting states;
  • (b) By virtue of any other agreement between both states;

The provisions of this agreement shall not prejudice the benefits or exemptions included in any bilateral or multilateral agreement between both states.

(2) As for paragraph (9) of Article 5 “permanent establishment”:

The two contracting states shall exchange information required to apply paragraph (9) of Article 5 to define the person who is closely connected.

This protocol was executed in duplicate at Abu Dhabi on Thursday corresponding to 14th Nov. 2019, in Arabic, both texts being equally authentic.

FOR THE GOVERNMENT OF UNITED ARAB EMIRATES:

OBAID HAMID AL TAYER

MINISTER OF FINANCE

FOR THE GOVERNMENT OF ARAB REPUBLIC OF EGYPT:

DR. HALA AL SAEED

MINISTER OF PLANNING, MONITORING AND ADMINISTRATIVE REFORM