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Double Tax Avoidance Agreement
"Need to draft a Double Tax Avoidance Agreement between UAE and Singapore, with specific focus on digital services taxation and e-commerce provisions, to be implemented by March 2025."
1. Parties: Identification of the contracting states (UAE and the other country) entering into the agreement
2. Background: Context of the agreement, including the desire to promote economic cooperation and eliminate double taxation
3. Definitions: Key terms used in the agreement, including 'resident', 'permanent establishment', 'dividends', 'interest', etc.
4. Scope of Agreement: Taxes and persons covered by the agreement
5. Residency: Rules for determining tax residency and handling dual residency cases
6. Permanent Establishment: Definition and conditions for constituting a permanent establishment
7. Income from Immovable Property: Taxation rights regarding income derived from real estate
8. Business Profits: Rules for taxation of business profits and attribution to permanent establishments
9. Shipping and Air Transport: Special provisions for international transport operations
10. Associated Enterprises: Transfer pricing and related party transaction provisions
11. Dividends, Interest, and Royalties: Taxation rights and rates for passive income
12. Capital Gains: Rules for taxation of gains from alienation of property
13. Elimination of Double Taxation: Methods for avoiding double taxation (credit or exemption method)
14. Non-discrimination: Provisions ensuring fair treatment of residents of both states
15. Mutual Agreement Procedure: Process for resolving disputes between tax authorities
16. Exchange of Information: Framework for information sharing between tax authorities
17. Entry into Force: When and how the agreement becomes effective
18. Termination: Conditions and procedures for terminating the agreement
1. Independent Personal Services: Special provisions for professional services, used when one country specifically requires separate treatment from business profits
2. Entertainers and Sportspersons: Special rules for taxation of entertainment and sports professionals, included when significant cross-border activity exists in these sectors
3. Petroleum Taxation: Special provisions for oil and gas activities, particularly relevant for UAE treaties
4. Islamic Finance Provisions: Specific provisions dealing with Islamic financial instruments, included when relevant to either party
5. Technical Services: Special provisions for technical service fees, included when significant technical service exchanges exist between countries
6. Limitation of Benefits: Anti-abuse provisions, included when treaty shopping is a concern
7. Government Service: Special provisions for government employees and services, included when significant government cooperation exists
8. Students: Special provisions for students and trainees, included when significant educational exchange exists
1. Schedule A - Taxes Covered: Detailed list of specific taxes in each contracting state covered by the agreement
2. Schedule B - Withholding Tax Rates: Table of applicable withholding tax rates for different types of income
3. Schedule C - Agreed Administrative Procedures: Detailed procedures for implementing the mutual agreement and information exchange provisions
4. Appendix 1 - Forms and Certificates: Standard forms for tax residency certificates and treaty benefit claims
5. Appendix 2 - Competent Authorities: List of designated competent authorities and their contact information
6. Protocol: Additional agreements or clarifications on specific articles of the main agreement
Authors
Other Contracting State
UAE
Person
Company
Enterprise
Enterprise of a Contracting State
International Traffic
Competent Authority
National
Tax
Fiscal Year
Resident
Permanent Establishment
Fixed Base
Business
Business Profits
Dividends
Interest
Royalties
Capital Gains
Immovable Property
Personal Services
Professional Services
Technical Services
Directors' Fees
Pension
Government Service
Student
Associated Enterprises
Place of Effective Management
Beneficial Owner
Political Subdivision
Local Authority
Tax Revenue
Protocol
Article
Connected Person
Income from Employment
Territory
Transfer Pricing
Islamic Financial Instrument
Zakat
Digital Services
Virtual Permanent Establishment
Hybrid Entity
Tax Treaty
Mutual Agreement Procedure
Residency
Permanent Establishment
Business Profits
Income from Immovable Property
Shipping and Air Transport
Associated Enterprises
Dividend Income
Interest Income
Royalty Income
Capital Gains
Employment Income
Directors' Fees
Entertainers and Athletes
Pensions and Annuities
Government Service
Students
Other Income
Elimination of Double Taxation
Non-discrimination
Exchange of Information
Mutual Agreement Procedure
Diplomatic and Consular Privileges
Anti-abuse Provisions
Limitation of Benefits
Entry into Force
Termination
Technical Services
Independent Personal Services
Force Majeure
Confidentiality
Amendment
Governing Law
Dispute Resolution
Notices
Language
Severability
Entire Agreement
Banking and Financial Services
International Trade
Oil and Gas
Manufacturing
Real Estate and Construction
Professional Services
Technology and Digital Services
Tourism and Hospitality
Aviation and Transportation
Healthcare
Education
Telecommunications
Retail and Consumer Goods
Media and Entertainment
Finance
Tax
Legal
Compliance
Treasury
International Business
Government Relations
Corporate Affairs
Risk Management
Strategy
Accounting
Regulatory Affairs
Tax Director
International Tax Manager
Chief Financial Officer
Tax Counsel
Finance Director
Corporate Tax Manager
Transfer Pricing Manager
Tax Policy Advisor
International Business Development Manager
Compliance Officer
Treasury Manager
Financial Controller
Tax Partner
International Tax Consultant
Government Relations Director
Diplomatic Attache
Treaty Negotiator
Cross-border Tax Specialist
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