background image
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

Elimination of Double Taxation

(1) Subject to the provisions of the laws of Liechtenstein regarding the elimination of double taxation, which shall not affect the general principle hereof, double taxation shall be eliminated as follows:

  • (a) Where a resident of Liechtenstein derives income or owns capital which, in accordance with the provisions of this Agreement, may be taxed in the United Arab Emirates, Liechtenstein shall, subject to the provisions of sub-paragraph (b), exempt such income or capital from tax, but may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempted income or capital.
  • (b) Where a resident of Liechtenstein derives items of income which, in accordance with the provisions of Articles 14, 15, 16 and 17, may be taxed in the United Arab Emirates, Liechtenstein shall credit against Liechtenstein tax on this income the tax paid in accordance with the law of the United Arab Emirates and with the provisions of this Agreement. The amount of tax to be credited shall not, however, exceed the Liechtenstein tax due on the income derived from the United Arab Emirates.

(2) Double taxation shall be eliminated in the United Arab Emirates as follows:

  • (a) Where a resident of the United Arab Emirates derives income or owns capital which, in accordance with the provisions of this Agreement, may be taxed in Liechtenstein, the United Arab Emirates shall allow:
    • (i) as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in Liechtenstein;
    • (ii) as a deduction from the tax on the capital of that resident, an amount equal to the capital tax paid in Liechtenstein.
  • (b) Such deduction in either case shall not, however, exceed that part of the income tax or capital tax, as computed before the deduction is given, which is attributable, as the case may be, to the income or the capital, which may be, taxed in Liechtenstein.

(3) Where in accordance with any provision of the Agreement income derived or capital owned by a resident of a Contracting State is exempt from tax in that State, such State may nevertheless, in calculating the amount of tax on the remaining income or capital of that resident, take into account the exempted income or capital.