Key Points of the Tax Convention with the United Arab Emirates

[Provisional translation]

1. Taxation on profits from business activities
   Where an enterprise has a permanent establishment (branch, etc.) and conducts business activities in a partner country, profits resulting from the business activities carried out through the permanent establishment is to be subject to tax in the country where the permanent establishment is situated.

1. Taxation on investment income in the source country
   Taxation on investment income (dividends, interest and royalties) in the source country is reduced as follows:

   Dividends		Interest	Royalties
   Between parent and subsidiary companies (shareholding requirement)	Others
   ５％（at least 10%）	10％	Exemption (received by Governments, etc.) 10％（others）	10％

1. Dispute resolution between the tax authorities
   Taxation not in accordance with the provisions of the Convention may be resolved by mutual agreement between the tax authorities of the two countries upon request by the taxpayer.

1. Exchange of Information between the tax authorities
   The Convention enables the tax authorities of the two countries to exchange information concerning all national and local taxes of the two countries.

1. Others
   The Convention also includes the provisions on:

   • (1) the appropriate adjustment for transfer pricing taxation;

   • (2) taxation on income derived by a silent partner in respect of a silent partnership contract; and

   • (3) prevention of abuse of the Convention.