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. dividends received by a Luxembourg companyfrom a UAE subsidiary, provided the Luxembourgcompany has directly held at least 10 per cent ofthe capital of the subsidiary since the beginning ofthe accounting year, andi. the subsidiary is subject in the UAE to anincome tax corresponding to the Luxembourgcorporation tax; orii. the subsidiary is exempt from tax, or taxed ata reduced rate in the UAE, but the dividendis derived out of profits from activities inagriculture, industry, infrastructure or tourismin the UAE.2. The protocol introduces an exemption fromLuxembourg net wealth tax with respect to aparticipation in a UAE company, if the conditions asset out under 1, letter b, are satisfied.3. The protocol amends the capital gains article of thetreaty. This amendment aims to clarify that capitalgains derived from the disposal of shares in listedcompanies are taxable only in the state of residenceof the seller.5. The protocol updates the list of qualifying financialinstitutions for both countries. Like states, localgovernments and local authorities, these specifiedfinancial institutions benefit from a 0% dividendwithholding tax rate under the treaty, provided theyare the beneficial owner of the dividend.The protocol shall enter into effect as of 1 January of theyear following the entry into force date of the protocol.The protocol will enter into force when both countrieshave exchanged the ratification instruments throughdiplomatic channels with each other.Tax treaty between UAE and ComorosIslands concluded26 March 2015 – The UAE and the Comoros Islandsconcluded a tax treaty and an investment protectionagreement with each other (in Sharm el-Sheikh, Egypt).The tax treaty contents are not public yet.UAE – Liechtenstein tax treaty initialed27 February 2015 – On 27 February 2015, Liechtensteinand the UAE initialed a tax treaty. More information is notyet public but will be reported once available.4. The protocol broadens the scope of the exchangeof information under the treaty. In line with OECDdevelopments, it will cover information that is‘foreseeable relevant’ to carry out the provisions ofthe treaty or to the administration or enforcementof the domestics laws concerning certain taxes orlevies. A provision will be introduced that stipulatesthat a contracting state, which is requested forinformation, is obliged to use its information gatheringmeasures to obtain the requested information, eventhough that state may not need that information forits own tax purposes. It has also been agreed that inno case a contracting state is permitted to decline tosupply information because the information is held bya bank, other financial institution, nominee or personacting in an agency or a fiduciary capacity or becauseit relates to ownership interest in a person.18
About Loyens & LoeffContactAt the heart of the legal and tax worldIndependent, international and specialised in Dutch, Belgian,Luxembourg and Swiss law. With offices in the Netherlands,Belgium, Luxembourg and Switzerland and branches in themost important global financial centres, Loyens & Loeff iscompletely at the heart of the legal and tax world.Your interest is our priorityWith a wealth of knowledge and experience gathered over theyears, we have been active in the legal and tax environmentsince the beginning of the 20th century. You can count onus to provide personal, tailored advice worldwide. Our 900advisers closely follow all developments and act quickly toturn them to your advantage. Directly, proactively and alwayswith your best interests as our priority. We combine ourknowledge and experience to create high-quality, creativeand efficient solutions. That way we can resolve your issueswith an innovative and pragmatic approach.Integrated and connectedWithin Loyens & Loeff, our legal and tax advisers work underthe same roof. That means that lawyers, tax advisers andcivil law notaries form cohesive teams and all challenges areapproached from various angles. Integrated and connected.We view matters from all perspectives that come with a fullservicepractice. We always consider the full range of optionsfor your situation, which offers you numerous advantages.Loyens & LoeffP.O. Box 506647, DubaiDubai International Financial Centre (DIFC), Gate Village,Building #10, Level 2, Office 202, DubaiUnited Arab EmiratesT +971 4 437 27 00F +971 4 425 56 73Jan Bart SchoberT +971 4 437 27 07M +971 56 179 67 76E jan.bart.schober@loyensloeff.comTim DopmeijerT +971 4 437 27 12M +971 502 403 453E tim.dopmeijer@loyensloeff.comwww.loyensloeff.comAlthough this publication has been compiled with great care, Loyens & Loeff N.V. and all other entities, partnerships, persons andpractices trading under the name ‘Loyens & Loeff’, cannot accept any liability for the consequences of making use of this issue withouttheir cooperation. The information provided is intended as general information and cannot be regarded as advice.19
Page 1 and 2: Middle East Newsletter2015 - Editio
Page 3 and 4: Dear Reader,Through this Middle-Eas
Page 5: Treaty between Bahrain and Cyprussi
Page 8 and 9: Qatar - Kenya tax treaty approved f
Page 11 and 12: Qatar - South Africa tax treaty con
Page 13: Access to the Saudi stock market re
Page 16 and 17: UAE - UK tax treaty update13 May 20
Page 20: AmsterdamArnhemBrusselsDubaiHong Ko

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