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PROTOCOL

At the moment of signing the Agreement between the Republic of Tajikistan and the United Arab Emirates for the avoidance of double taxation with respect to taxes on income and on capital, the undersigned have agreed that the following provisions shall form an integral part of the Agreement.

(1) Ad Article 4:

It is understood that the term "resident of a Contracting State" used in the first sentence of paragraph (1) includes that State itself, any political subdivisions or local authority thereof, as well as any financial institution of, and controlled by, that State, political subdivision or local authority.

(2) Ad Article 7:

Where an enterprise of a Contracting State derives profits from the extraction of petroleum or other natural resources or from related activities therewith in the other Contracting State though a permanent establishment as defined in sub-paragraph (f) of paragraph (2) of Article 5, nothing in the Agreement shall affect the right of that other State to apply its internal taxation laws with respect of the profits attributable to the permanent establishment.

(3) Ad Article 14:

The remuneration derived by an employee of an enterprise of a Contracting State operating ships or road transport vehicles aircraft in international traffic in respect of an employment directly connected with such operations shall be taxable only in that State where that employee is a national of that State without being also a national of the other State.

(4) If under any convention or agreement, or protocol to a convention or agreement, signed after the signature of this Agreement, between Republic of Tajikistan and any member State of the Cooperation Council of the Gulf Arab State, or between the Republic of Tajikistan and a third State, the Republic of Tajikistan accords, as regards the provisions of this Agreement, a more favourable than that accorded to residents of the United Arab Emirates under this Agreement, then as from the date on which the relevant convention or agreement or protocol enters into force the same favourable treatment shall automatically be applied to the residents of the United Arab Emirates under this Agreement. The same treatment shall be accorded to the Republic of Tajikistan residents but excluding those benefits that are accorded to the residents of the Gulf Arab States Co-operation Council.

(5) Ad Article 8:

The two Contracting States shall exchange through diplomatic channels the list of air and shipping transport enterprises which they own or participate in their capital.

DONE at Abu Dhabi, this seventeenth day of December 1995, corresponding to the twenty-fifth day of Rajab 1416 A.H., in two originals in the English language.

FOR THE GOVERNMENT OF THE REPUBLIC OF TAJIKISTAN:

GAFAROF TUKHTABOY

FOR THE GOVERNMENT OF THE UNITED ARAB EMIRATES:

AHMAD HUMAID AL TAYER