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ARTICLE 28

Income of Government and Institutions

(1) The Federal or the Local Governments and their financial institutions of either Contracting States shall be exempt from tax in the other Contracting State in respect of any income or capital gains derived by such federal or Local Government from that other Contracting State except income from hydrocarbon as stated in Article 22.

(2) For the purpose of paragraph 1 of this Article, the entities listed below qualify for the exemptions from tax on income and gains derived from dividends, interest, royalties and capital gains:

  • (a) In the case of the United Arab Emirates:
    • (1) Central Bank of the United Arab Emirates;
    • (2) Abu Dhabi Investment Authority;
    • (3) Abu Dhabi Investment Council;
    • (4) Emirates Investment Authority;
    • (5) Mubadala Investment Company;
    • (6) Mubadala Development Company and its successors and assigns;
    • (7) International Petroleum Investment Company (IPIC) and its successors and assigns;
    • (8) Investment Corporation of Dubai;
    • (9) the Abu Dhabi Retirement Pensions and Benefits Fund;
    • (10) the General Pension and Social Security Authority; and
  • any other entity the capital of which is directly or indirectly wholly owned by the federal or local Governments of the United Arab Emirates, including a political subdivision and local authority thereof through notifications by the competent authorities through diplomatic channels.
  • (b) In case of the Republic of Moldova:
    • (1) the Government, central administrative authorities, local authorities and agencies;
    • (2) the National Bank of Moldova;
    • (3) State owned enterprises;
    • (4) State owned companies which shares are held for at least 50% by the Government of the Republic of Moldova, and
  • any other entity the capital of which is directly or indirectly wholly owned by the central or local Governments of the Republic of Moldova, including a political subdivision and local authority thereof through notifications by the competent authorities through diplomatic channels.