At the time of signing of the Agreement between the Government of jersey and the Government of the United Arab Emirates for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income ("the Agreement"), the two Governments have agreed on the following provisions which shall form an integral part of the Agreement.
The Government of Jersey and the Government of the United Arab Emirates, confirm that:
(1) The Government of Jersey observes the principle of sovereign immunity from taxation.
(2) Nothing in the Agreement which has been concluded between the Governments of Jersey and the United Arab Emirates will affect the provision by Jersey of sovereign immunity from income tax, corporation tax and capital gains tax in respect of income and chargeable gains beneficially owned by:
- (i) the Government of the United Arab Emirates;
- (ii) a local Government of the United Arab Emirates (Abu Dhabi, Dubai, Sharjah, Ras al Khaimah, Fujairah, Umm al Qaiwain and Ajman); or
- (iii) an agency of the federal or local Government which is agreed to form an integral part of the Government of the United Arab Emirates or an integral part of one of its local Governments.
(3) The following institutions are recognised as an integral part of the the U.A.E. local Governments:
- (i) Central Bank of the United Arab Emirates,
- (ii) Emirates Investment Authority,
- (iii) Abu Dhabi Investment Authority,
- (iv) International Petroleum Investment Company (IPIC);
- (v) Abu Dhabi Investment Council,
- (vi) Investment Corporation of Dubai,
- (vii) Mubadala Development Company,
- (viii) the Abu Dhabi Retirement Pensions and Benefits Fund
- (ix) the General Pension and Social Security Authority,
and any other institutions that shall be agreed between the two Contracting States through exchange of letters.
IN WITNESS WHEREOF, the undersigned, being duly authorised thereto by their respective Governments, have signed this Protocol.
DONE in duplicate at Dubai, this twentieth day of April 2016, in two originals, in Arabic and in the English language.
FOR THE GOVERNMENT OF JERSEY:
FOR THE GOVERNMENT OF THE U.A.E.: