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PROTOCOL

At the signing today of the Agreement between the United Arab Emirates and the Republic of Finland for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income (hereinafter referred to as "the Agreement"), the undersigned have agreed upon the following provisions which shall form an integral part of the Agreement:

(1) With reference to Article 4, paragraph (2):

Any inter-governmental entity with equity capital or other capital of a similar nature in which the United Arab Emirates subscribes together with other states shall be entitled to the benefits of the Agreement, but only to the extent that corresponds to the participation of the United Arab Emirates in such capital.

(2) With reference to Articles 6 and 13:

Income from the direct use, letting, or use in any other form of a right to enjoyment of immovable property situated in Finland and held by a company, being a resident of Finland and other than such the shares of which are quoted on an approved stock exchange, derived by a shareholder in the company, or capital gains derived from the alienation of shares or other corporate rights, other than shares quoted on an approved stock exchange, in a company the assets of which consist mainly of immovable property situated in Finland may be taxed in Finland.

(3) With reference to Articles 8 and 13:

The provisions of Articles 8 and 13 shall also apply to profits from the operation of ships or aircraft in international traffic and capital gains from the alienation of such ships or aircraft, derived by Gulf Air or Arab Shipping Company or any other enterprise formed by a resident of a Contracting State together with a resident of a third state, but only to such part of the profits or gains as corresponds to the participation held by the resident of a Contracting State.

(4) With reference to Article 10, paragraph (3), Article 11, paragraph (3), and Article 12, paragraph (3):

If, in an Agreement for the avoidance of double taxation that is subsequently concluded between Finland and a third state, Finland agrees that residents of that third state are, with regard to dividends, interest or royalties paid in respect of a holding, debt-claim, or a right or property, respectively, effectively connected with a permanent establishment which such resident has in Finland, entitled to more favorable treatment than that provided under paragraph (3) of Article 10, paragraph (3) of Article 11 or paragraph (3) of Article 12, then the Government of the Republic of Finland shall without undue delay inform the Government of the United Arab Emirates in writing through the diplomatic channel and shall enter into negotiations with the Government of the United Arab Emirates with a view to providing the same treatment for residents of the United Arab Emirates as that provided for residents of the third state.

(5) With reference to Article 21:

Subject to the provisions of Article 21, nothing in this Agreement shall affect the right of the Government of the United Arab Emirates, its political subdivisions, local governments or local authorities to apply its own laws related to the taxation of income derived from the operation and exploitation of petroleum and other natural resources. Such income shall be taxed according to the laws of the United Arab Emirates.

(6) With reference to Article 27:

Notwithstanding the provisions of Article 27 of the Agreement, the provisions of Article 8 of the Agreement shall have effect in respect of taxes chargeable on profits derived on or after 1 January 1992 from the operation of ships or aircraft in international traffic.

IN WITNESS WHEREOF the undersigned, duly authorised thereto, have signed this Agreement.

DONE in duplicate at Abu Dhabi this 12th day of March 1996, in the Finnish, Arabic and English languages, all three texts being equally authentic. In the case of divergence of interpretation the English text shall prevail.

FOR THE GOVERNMENT OF THE REPUBLIC OF FINLAND:

OLE NORRBACK

MINISTER

FOR THE GOVERNMENT OF THE UNITED ARAB EMIRATES:

AHMED HUMAID AL TAYER

STATE MINISTER FOR FINANCE & INDUSTRY