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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.



(1) Interest arising in a Contracting State and paid to a resident of the other Contracting State may be taxable in that other State.

(2) However, interest paid by a company which is a resident of a Contracting State may also be taxed in that Contracting State according to the laws of that Contracting State, but If the beneficial owner of the interest is a resident of the other Contracting State, the tax so charged shall not exceed 10 percent of the gross amount of the interest.

(3) Notwithstanding the provisions of paragraphs 1 and 2 of this Article interest arising in a Contracting State shall be exempt from tax in that Contracting State provided it is derived and beneficially owned by:

  • (a) in the case of the Slovak Republic:
    • (i) the Government of the Slovak Republic,
    • (ii) the local authorities,
    • (iii) Narodna banka Slovenska (the National Bank of Slovakia),
    • (iv) Eximbanka SR (Export-import Bank of the Slovak Republic),
    • (v) Slovenska zarucna a rozvojova banka, a.s. (Slovak Guarantee and Development Bank),
    • (vi) Agentura pre riadenie dlhu a likvidity (Debt and Liquidity Management Agency),
  • (b) in case of the United Arab Emirates;
    • (i) Central Bank of the United Arab Emirates,
    • (ii) Emirates Investment Authority,
    • (iii) Abu Dhabi Investment Authority,
    • (iv) International Petroleum Investment Company (IPIC),
    • (v) Abu Dhabi Investment Council,
    • (vi) Investment Corporation of Dubai,
    • (vii) Abu Dhabi National Energy Company (TAQA),
    • (viii) Mubadala Development Company,
    • (ix) the Abu Dhabi Retirement Pensions and Benefits Fund,
    • (x) the General Pension and Social Security Authority,
  • and any other institutions that shall be agreed between the two Contracting States through exchange of letters.

(4) The term "interest" as used in this Article means income form debt-claims of every kind, whether or not secured by mortgage and whether or not carrying a right to participate in the debtor's profits, and in particular, income from government securities and income from bonds or debentures, including the premiums and prizes attaching to such securities, bonds or debentures. Penalty charges for late payments shall not be regarded as interest for the purpose of this Article.

(5) The provisions of paragraphs 1, 2 and 3 of this Article shall not apply if the beneficial owner of the interest, being a resident of a Contracting State, carries on business in the other Contracting State in which the interest arises through a permanent establishment situated therein, and the debt-claim in respect of which the interest is paid is effectively connected with such permanent establishment. In such case the provisions of Article 8, as the case may be, shall apply.

(6) Interest shall be deemed to arise in a Contracting State when the payer is a resident of that State. Where, however, the person paying the interest, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the indebtedness on which the interest is paid was incurred, and such interest is borne by such permanent establishment, then such interest shall be deemed to arise in the State in which the permanent establishment is situated.

(7) Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interest, having regard to the debt-claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.