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Untd A Emirates - Rwanda Tax Treaty (2017, not yet in force) — Orbitax Tax Hub

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 24

Elimination of Double Taxation

(1) Double Taxation shall be eliminated in the Contracting States as follows:

  • (a) In United Arab Emirates:
  • Where a resident of a Contracting State derives income or owns capital which, in accordance with the provisions of this Agreement, may be taxed in the other Contracting State, the first-mentioned State shall allow:
    • (a) as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in that other State;
    • (b) as a deduction from the tax on the capital of that resident, an amount equal to the capital tax paid in that other State.
  • 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 that other State.
  • (b) in Rwanda:
    • UAE tax paid by a resident of Rwanda in respect of income taxable in UAE, in accordance with the provisions of this Agreement, shall be deducted from taxes due in accordance with Rwandan Tax Law (which shall not affect the general principle hereof). Such deduction shall not, however, exceed the tax payable in Rwanda that would otherwise be payable on the income taxable in UAE.

(2) Where in accordance with any provision of the Convention 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.

(3) For the purposes of paragraph (1), the terms "Rwanda tax paid" and "UAE tax paid" shall be deemed to include the amount of tax which would have been paid in Rwanda or UAE as the case may be, but for an exemption or reduction granted in accordance with laws which establish schemes for the promotion of economic development in Rwanda or UAE, as the case may be, such schemes having been mutually agreed by the competent authorities of the Contracting States as qualifying for the purposes of this paragraph.