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Application of the MLI to the Tax Treaty between Japan and the United Arab Emirates

 The MLI enters into force for Japan on January 1, 2019, and for the United Arab Emirates on September 1, 2019.
 Based on the reservations and notifications submitted by Japan on September 26, 2018 and by the United Arab Emirates on May 29, 2019, the MLI applies to the tax treaty between Japan and the United Arab Emirates as described below.

1. Tax treaty covered by the MLI
    - “Convention between Japan and the United Arab Emirates for the Avoidance of Double Taxation and the
  Prevention of Fiscal Evasion with respect to Taxes on Income”
  Date of signature: May 2, 2013
  Date of entry into force: December 24, 2014

2. Provisions of the MLI applicable to the tax treaty
    - Article 6(1) (Preamble language describing the intent of the Contracting Jurisdictions that the tax treaty will not
      create opportunities for non-taxation or reduced taxation)
    - Article 6(3) (Preamble language referring to a desire of the Contracting Jurisdictions to develop their economic
      relationship and to enhance their co-operation in tax matters)
    - Article 7(1) (Provisions that deny the benefits under the tax treaty where the principal purpose or one of the
      principal purposes of any arrangement or transaction was to obtain those benefits)
    - Article 16(1), 1st sentence (Provisions for presentation of a case of taxation not in accordance with the provisions
      of the tax treaty for a mutual agreement procedure)
    - Article 17(1) (Provisions regarding corresponding adjustments to taxation in accordance with arm’s length
      principle)
  
3. Entry into effect
  (a)  The provisions of the MLI shall have effect in each Contracting Jurisdiction with respect to the tax treaty between
        Japan and the United Arab Emirates:
      (i)   with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving
            rise to such taxes occurs on or after January 1, 2020; and
      (ii)   with respect to all other taxes levied by that Contracting Jurisdiction, for taxes levied with respect to taxable
             periods beginning on or after March 1, 2020.
  (b)  Notwithstanding (a), Article 16 (Mutual Agreement Procedure) shall have effect with respect to the tax treaty
        between Japan and the United Arab Emirates for a case presented to the competent authority of a Contracting
        Jurisdiction on or after September 1, 2019, except for cases that were not eligible to be presented as of that
        date under the tax treaty between Japan and the United Arab Emirates prior to its modification by the MLI,
        without regard to the taxable period to which the case relates.