At the time of signing the Agreement between the United Arab Emirates and the Gabonese Republic for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income, the undersigned have agreed that the following shall form an integral part of the Agreement:
(1) With respect to Articles, 11, 12, 14 and 15 it is understood that the entities listed below qualify as government entities, and their income and gains shall be taxable only in the Contracting State where they are resident:
- (a) In the case of the United Arab Emirates:
- (1) Central Bank of the United Arab Emirates;
- (2) Abu Dhabi Investment Authority;
- (3) Abu Dhabi Investment Council;
- (4) Emirates Investment Authority;
- (5) Mubadala Investment Company;
- (6) Dubai World;
- (7) Investment Corporation of Dubai;
- (8) Abu Dhabi National Energy Company (TAQA);
- (9) The Abu Dhabi Retirement Pensions and Benefits Fund;
- (10) The General Pension and Social Security Authority; and
- any other entity the capital of which is directly or indirectly wholly owned by the federal or local Governments of the United Arab Emirates, including a political subdivision and local authority thereof through notifications by the competent authorities through diplomatic channels.
- (b) In case of the Gabonese Republic:
- (1) The list shall be sent through diplomatic channels at any time including any other future funds of which the capital of which is directly or indirectly wholly owned by the federal or local Governments of the Gabonese Republic, including a political subdivision and local authority thereof through notifications by the competent authorities through diplomatic channels.
- (2) If after signature of this Agreement between the Gabonese Republic and the United Arab Emirates, the Gabonese Republic or the United Arab Emirates concludes an Agreement with any other country that accords substantial provisions providing a treatment more favourable than that accorded to residents of a Contracting State under this Agreement the Contracting States shall notify each other and automatically shall be applied to the residents of the other Contracting State.
IN WITNESS WHEREOF, the undersigned, duly authorized thereto by their respective Governments, have signed this Protocol.
DONE at Abu Dhabi on 01 March 2019, in two originals Arabic, French and the English language. In case if divergence between the texts the English text shall prevail.
FOR THE GOVERNMENT OF THE UNITED ARAB EMIRATES:
FOR THE GOVERNMENT OF THE GABONESE REPUBLIC: