background image

Untd A Emirates - Suriname Tax Treaty (2018, not yet in force) — Orbitax Tax Hub

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.

PROTOCOL

At the moment of signing the Agreement between the Government of the United Arab Emirates and the Government of the Republic of Suriname for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income, the Government of the United Arab Emirates and the Government of the Republic of Suriname have agreed that the following provisions shall form an integral part of the Agreement.

(1) With respect to Article 30, its understood that government institutions shall be subject to tax at the state of residence with respect to paragraph (9) of Article 8 (Business Profits), paragraph (1) of Article 7 (Income from Immovable Property), paragraph (2) of Article 11 (Dividends), paragraph (2) of Article 12 (Interest), paragraph (2) of Article 13 (Royalties), paragraph (2) of Article 14 (Management Fees) and paragraphs (1) and (2) of Article 15 (Capital Gains) of this Agreement, it is understood that the Contracting State, political subdivisions, local authorities, entities or Article 5, paragraph (2) statutory bodies thereof wholly owned directly or indirectly by that Government shall also include:

  • (a) In case of the United Arab Emirates:
    • (i) Central Bank of the United Arab Emirates;
    • (ii) Abu Dhabi Investment Authority;
    • (iii) Abu Dhabi Investment Council;
    • (iiii) Emirates Investment Authority;
    • (v) Mubadala Investment Company;
    • (vi) Investment Corporation of Dubai;
    • (vii) the Abu Dhabi Retirement Pensions and Benefits Fund;
    • (viii) the General Pension and Social Security Authority; and
  • any other entity the capital of which is wholly or partially directly or indirectly owned by the federal or local Governments of the United Arab Emirates, including a political subdivision and local authority thereof which shall be exchanged between the Contracting States through the diplomatic channels.
  • (b) In the case of the Republic of Suriname:
    • (i) Central Bank of Suriname;
    • (ii) Saving and Stabilization Fund Suriname;
    • (iii) INVESTUR; and
    • (iiii) General Pension Fund.

any other entity the capital of which is wholly or partially directly or indirectly owned by the federal or local Government of the Republic of Suriname, including a political subdivision and local authority thereof which shall be exchanged between the Contracting States through the diplomatic channels.

(2) For greater certainty government institutions mentioned in Article 30 shall be considered as those mentioned in this Protocol.

(3) Notwithstanding any other provisions of this Agreement, it’s understood that the Suriname Investment Act 2001 related to incentives to the investors shall be applied.

IN WITNESS WHEREOF, the undersigned, duly authorized thereto by their respective Governments, have signed this Protocol.

DONE at [...] on [4 November], 2018, in three originals Arabic, Dutch and the English languages, all texts equally authentic. In case of divergence between the three texts the English text shall prevail.