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Untd A Emirates - France Tax Treaty (as amended by 1993 protocol) — Orbitax Tax Hub

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 18

Specific Provisions

#(1) Investments made by one State in the other State (including those of the Central Bank and of public institutions) and the income derived from such investments (including gains from their alienation) shall be exempt from tax in that other State. The provisions of this paragraph shall not apply to immovable property or the income-including gains-derived therefrom.

*(2) Nothing in this Convention shall prevent the application of any more favourable tax regime which might be provided for by the French domestic law in force in respect of foreign public investment.

*(3) Individuals who are residents of the United Arab Emirates and who have at their disposal one or more dwellings for their private use in France, without having their fiscal domicile therein for the purposes of French legislation, shall be exempt from tax on the income established on the basis of the rental value of the dwelling or dwellings.

*(4) Interest, royalties and other costs paid by an enterprise of one State to a resident of the other State shall be deductible in the determination of the taxable profits of that enterprise on the same conditions as if they had been paid to a resident of the first-mentioned State.

*(5) If a person who is a resident of one State for the purposes of the domestic legislation of that State is deemed to be a resident of the other State on the basis of the criterion of nationality referred to in Article 4, paragraph (2)(c), the first-mentioned State may refuse to grant that person the tax exemptions or reductions provided for in the Convention in respect of residents of the other State, but shall nevertheless treat that person as a non-resident for the purposes of the application of its domestic law.

#(6) The provisions of the Convention shall in no manner prevent or limit the application by France-in respect of its residents other than citizens of the United Arab Emirates-of the provisions of its domestic laws aimed at preventing or punishing tax evasion or fraud.

#(7) It shall be understood that the provisions of Article 4 of the Agreement between the French Republic and the State of the United Arab Emirates on the reciprocal promotion and protection of investments, signed on 9 September 1991, shall not apply to fiscal matters.