PROTOCOL

While signing the Convention concluded between the government of UAE and the government of IQ on the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income and capital (referred to herein as the "Convention"), the undersigned agreed upon the following additional provisions and considered them an integral part of the Convention:

(1) In respect of sub-paragraph (2) of Article (1):

• (a) It is understood that in the case of the United Arab Emirates, “government institutions” shall be, for example, but not limited to, the Abu Dhabi Investment Authority ADIA, Dubai World, Mubadala Investment Company (Mubadala), Investment Corporation of Dubai ICD, Emirates Investment Authority and the International Petroleum Investment Company (IPIC).
• (b) It is understood that government institutions owned by both countries will be exempt from the tax imposed on shares, profits and capital gains in accordance with paragraph (5) of Article 14.

(2) It is understood that if there is any legislation in either country that gives tax advantages represented in exemption from taxes contains advantages more favorable than those stipulated in the provision of this Convention, such advantages shall apply to taxpayers in both Contracting States.

(3) In the event that either of the two Contracting States concludes a Convention for the avoidance of double taxation from any third party that contains advantages more favorable than those stipulated in this Convention, such advantages shall apply to taxpayers in both Contracting States, with the exception of agreements signed between the State of the United Arab Emirates And the countries of the Co-operation Council for the Arab States of the Gulf.

IN WITNESS WHEREOF, this attached protocol was hereunder signed by the representatives duly authorized for this purpose.

DONE, in duplicate, in Abu Dhabi, on the 3rd day of October of the year 2017, in the Arabic language, and both texts are of equal authenticity.

FOR THE GOVERNMENT OF UNITED ARAB EMIRATES:

ANWAR MOHAMMED GARGASH              

MINISTER OF STATE FOR FOREIGN AFFAIRS                

FOR THE GOVERNMENT OF IRAQ:

DR. IBRAHIM ABD AL-ESHAIKER AL-JAAFARI

MINISTER OF FOREIGN AFFAIRS