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Untd A Emirates - Iraq Tax Treaty (2017, not yet in force) — 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 11

Dividends

(1) Dividends paid by a company resident in a Contracting State to a resident of the other Contracting State may be taxable only in the other Contracting State.

(2) The term "Dividends" herein shall mean income from shares Equity Shares/rights of “Equity”, “amendment Shares”, “Founders' shares” or other rights that share in income and not debt, as well as the income of other contribution rights which are subject to similar taxes as they are deemed an income of the shares in accordance with the law of the State where the profit-distributing company is situated.

(3) The State shall not make the profits of the undistributed company subject to tax even if the profits undistributed represent, wholly or partly, profits or income generated in the other State.