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PROTOCOL

At the signing of the Agreement between the Government of the United Arab Emirates and the Government of the Republic of Giunea for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital, both sides have agreed that this Protocol shall form an integral part of the Agreement:

With reference to Article 27:

It is understood that governmental institutions of the United Arab Emirates shall include particulary but not exclusivly the following types of entities created under public law which are wholly owned and controled by the United Arab Emirates, local governments, political subdivision or local authoroties:

  • (i) UAE Central Bank;
  • (ii) Abu Dhabi Investment Authority;
  • (iii) Abu Dhabi Investment Council;
  • (iv) International Petroleum Investment Company;
  • (v) Dubai Investment Office;
  • (vi) UAE Investment Authority;
  • (vii) Abu Dhabi Fund for Economic Development;
  • (viii) Mobadalah;
  • (ix) Dubai Holding;
  • (x) Dubai World;
  • (xi) Any other further institutions shall be recognised as governmental institutions by exchange of letters.

IN WITNESS WHEREOF, the undersigned, duly authorized thereto by their respective Governments, have signed this Protocol.

DONE in duplicate at Abu Dhabi, United Arabs Emirates, This day of 13 November 2011, corresponding to, French, Arabic and English languages, and all texts being equally authentic. In case of divergency of the interpretation, the English text shall prevail.

FOR THE GOVERNMENT OF THE UNITED ARAB EMIRATES:

OBAID HUMAID AL TAYER

MINISTER OF STATE FOR FINANCIAL AFFAIRS

FOR THE GOVERNMENT OF THE REPUBLIC OF GUINEA:

DOCTOR/EDOUARD NIANKOYE LAMA

MINISTER OF FOREIGN AFFAIRS