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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 2

Taxes Covered

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

(2) There shall be regarded as taxes on income and on capital all taxes imposed on total income, on total capital, or on elements of income or of capital, including taxes on gains from the alienation of movable or immovable property as well as taxes on capital appreciation.

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

  • (a) in the case of the United Arab Emirates:
    • (i) the income tax; and
    • (ii) corporation tax;
  • (hereinafter referred to as "United Arab Emirates tax");
  • (b) in the case of the Republic of Seychelles:
    • (i) the business tax; and
    • (ii) the petroleum income tax;
  • (hereinafter referred to as "Seychelles tax").

(4) This Agreement shall also apply to any identical or substantially similar taxes, which are imposed 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 the respective taxation laws within a reasonable period of time after such changes.