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ARTICLE 23

Elimination of Double Taxation

Double taxation shall be eliminated as follows:

(1) In the case of Mauritius:

  • (a) Where a resident of a Contracting State derives income from the United Arab Emirates the amount of tax on that income payable in the United Arab Emirates in accordance with the provisions of this Agreement may be credited against the Mauritius tax imposed on that resident.
  • (b) Where a company which is a resident of United Arab Emirates pays a dividend to a resident of Mauritius who controls, directly or indirectly, at least 5% of the capital of the company paying the dividend, the credit shall take into account (in addition to any UAE tax for which credit may be allowed under the provisions of sub-paragraph (a) of this paragraph) the UAE tax payable by the first-mentioned company in respect of the profits out of which such dividend is paid.

Provided that any credit allowed under sub-paragraphs (a) and (b) shall not exceed the Mauritius tax (as computed before allowing any such credit), which is appropriate to the profits or income derived from sources within the United Arab Emirates.

(2) In the case of United Arab Emirates, where a resident of the United Arab Emirates derives income which, in accordance with the provisions of this Agreement, may be taxed in Mauritius, the United Arab Emirates shall exempt such income from tax.

(3) For the purposes of allowance as a credit the tax payable in the United Arab Emirates shall be deemed to include the tax which is otherwise payable in United Arab Emirates but has been reduced or waived by United Arab Emirates in order to promote its economic development.