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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.

ARTICLE 23

Income of Government Institutions

(1) Notwithstanding any other provisions in this Agreement except Article 3, the Government of the Contracting State shall be exempt from tax in the other Contracting State in respect of any income derived by such Government from that other Contracting State.

(2) For the purposes of paragraph (1) of this Article, the term "Government":

  • (a) In the case of Georgia:
    • (i) the Government, or a local authority;
    • (ii) the National Bank of Georgia; and
    • (iii) any other governmental agencies, political subdivisions, or institutions of Georgia as may be specified and agreed to in an exchange of letters between the competent authorities of the Contracting States.
  • (b) In the case of the U.A.E., means the Government of the United Arab Emirates, and shall include:
    • (i) the political subdivisions, the local authorities, the local administrations, and the local governments;
    • (ii) the Central Bank of the U.A.E., Abu Dhabi Investment Authority, Abu Dhabi Development Fund, Abu Dhabi Investment Council, Emirates Investment Authority, Dubai World and pension Fund;
    • (iii) any such institution or body as may be agreed from time to time between the two Contracting States.