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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
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