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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.


Taxes Covered

(1) This Agreement shall apply to taxes on income imposed on behalf of a Contracting State or of its political subdivisions or local authorities, irrespective of the manner in which they are levied.

(2) There shall be regarded as taxes on income and on capital gains all taxes imposed on total income, on total capital, or on elements of income or capital, including taxes on gains from the alienation of movable or immovable property and taxes on the total amounts of wages or salaries paid by enterprises.

(3) The existing taxes to which this Agreement shall apply are, in particular:

  • (a) In the case of UAE:
    • (1) The Income Tax;
    • (2) The Corporate Tax;
  • (hereinafter referred to as "UAE tax");
  • (b) in the case of the Federal Republic of Nigeria:
    • (1) The Personal income Tax;
    • (2) The Companies income Tax;
    • (3) The Petroleum Profit Tax;
    • (4) Capital Gains Tax;
    • (5) Tertiary Education Tax;
    • (6) Information Technology Levy.
  • (hereinafter referred to as "the Federal Republic of Nigeria tax");

(4) This Agreement shall apply also to any identical or substantially similar taxes, which are imposed under the laws of a Contracting State after the date of signature of this Agreement in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify each other of any significant changes, which have been made in their respective taxation laws.