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PROTOCOL

At the moment of signing the Agreement between the Government of the United Arab Emirates and the Government of the Republic of Croatia for the avoidance of double taxation with respect to taxes on income, the undersigned have agreed upon the following provisions which shall be an integral part of the Agreement.

Article 1:

With reference to Article 5 (Resident), Article 11, paragraph 3 (Dividends) and Article 12, paragraph 3 (Interest) the term "financial institution" shall include:

(1) in the case of the Republic of Croatia:

  • (a) Croatian National Bank; and
  • (b) any other entity or statutory body, agency or instrumentality, the capital of which is wholly owned, directly or indirectly, by the Republic of Croatia or its local authorities, as shall be certified from time to time between the Governments of the Contracting States through notifications by the competent authorities;

(2) in the case of the United Arab Emirates.

  • (a) Central Bank of the United Arab Emirates;
  • (b) Abu Dhabi Investment Authority;
  • (c) Abu Dhabi Investment Council;
  • (d) Emirates Investment Authority;
  • (e) Mubadala Development Company;
  • (f) International Petroleum Investment Company (IPIC);
  • (g) Dubai World;
  • (h) Investment Corporation of Dubai;
  • (i) the Abu Dhabi Retirement Pensions and Benefits Fund;
  • (j) the General Pension and Social Security Authority;
  • (k) Al Dahra Holding Company;
  • (l) Abu Dhabi National Energy Company (TAQA); and
  • (m) any other entity or statutory body, agency or instrumentality, the capital of which is wholly owned, directly or indirectly, by the federal or the local governments of the United Arab Emirates, including local authorities thereof, as shall be certified from time to time between the Governments of the Contracting States through notifications by the competent authorities.

Article 2:

With reference to Article 14, it is understood that paragraph 4 shall include capital gains from the alienation of shares or comparable interest in company other than those referred to in paragraph 2 and 3 that is derived by a resident of a Contracting State or its financial institutions listed in Article 1 of this Protocol.

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

DONE at Zagreb on 13 July 2017 in two original copies, each in the Croatian, Arabic and English languages, all texts being equally authentic. In case of any divergence of interpretation, the English text shall prevail.

FOR THE GOVERNMENT OF THE UNITED ARAB EMIRATES:

ABDULLAH BIN ZAYED AL NAHYAN

MINISTER OF FOREIGN AFFAIRS & INTERNATIONAL CO-OPERATION

FOR THE GOVERNMENT OF THE REPUBLIC OF CROATIA:

MR ZDRAVKO MARIC, PH.D.

MINISTER OF FINANCE