On July 1st, 2021 a Protocol to the existing double tax treaty between Austria and the UAE (United Arab Emirates) was signed. The Protocol will introduce a dividend withholding tax exemption for dividends paid to a beneficial owner that is the other State itself, a political subdivision or local authority thereof, or a qualified government entity. Some of the worlds largest sovereign wealth funds in the UAE are specifically qualified as government entities.

The term “qualified government entity” shall mean any entity or institution which is wholly owned directly or indirectly, by the federal or local government, a political subdivision, or a local authority thereof and shall include the following entities:

in the case of the UAE:

• Central Bank of the United Arab Emirates,

• Emirates Investment Authority

• Abu Dhabi Investment Authority

• Abu Dhabi Investment Council,

• Investment Corporation of Dubai,

• Mubadala Investment Company,

• Abu Dhabi Developmental Holding Company (ADQ),

• International Petroleum Investment Company (IPIC),

• the Abu Dhabi Retirement Pensions and Benefits Fund,

• the General Pension and Social Security Authority;

A list of entities the capital of which is wholly owned directly or indirectly, by the UAE, by the federal or local government, a political subdivision, or a local authority thereof, and which as such are eligible for the withholding tax exemption for sovereign wealth funds shall be exchanged from time to time between the Contracting States through notifications by the competent authorities