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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 27

Elimination of Double Taxation

(1) In Latvia, double taxation shall be eliminated as follows:

  • (a) Where a resident of Latvia derives income or owns capital which, in accordance with this Convention, may be taxed in the United Arab Emirates, unless a more favourable treatment is provided in its domestic law, Latvia shall allow:
    • (i) as a deduction from the tax on the income of that resident, an amount equal to the income tax paid thereon in the United Arab Emirates;
    • (ii) as a deduction from the tax on the capital of that resident, an amount equal to the capital tax paid thereon in the United Arab Emirates.
  • Such deduction in either case shall not, however, exceed that part of the income tax or capital tax in Latvia, 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 the United Arab Emirates.
  • (b) For the purposes of subparagraph (a), where a company that is a resident of Latvia receives a dividend from a company that is a resident of the United Arab Emirates in which it owns at least 10 per cent of its shares having full voting rights, the tax paid in the United Arab Emirates shall include not only the tax paid on the dividend, but also the appropriate portion of the tax paid on the underlying profits of the company out of which the dividend was paid.

(2) In the United Arab Emirates, double taxation shall be eliminated as follows:

  • (a) Where a resident of the United Arab Emirates derives income or owns capital which in accordance with the provisions of this Convention may be taxed in Latvia, the United Arab Emirates shall allow as a deduction from tax on income or on capital of that person an amount equal to the tax on income or tax on capital paid in Latvia.
  • (b) Such deductions in either case shall not, however, exceed that part of 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 Latvia.