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 23
Income of Governments and their Authorities
(1) Any revenues generated by a Contracting State government shall be exempted from any taxes or duties imposed in the other Contracting state.
(2) For purposes of paragraph (1) hereof, the term "government" shall mean:
- (a) For SAR: the Syrian government which includes:
- (i) the local authorities and municipalities;
- (ii) the Central Bank - and the Syrian Commercial Bank and its branches;
- (iii) any institution or authority as agreed upon from time to time between both Contracting States;
- (b) For UAE, the government of UAE which includes:
- (i) political divisions, local authorities, municipalities and local governments;
- (ii) the Central Bank of UAE, Abu Dhabi Investment Authority and Abu Dhabi Fund for Development;
- (iii) any institution or authority as agreed upon from time to time between both Contracting States.