JULY 27, 2021 | TAX NEWS
On July 1st, a Protocol to the tax treaty between Austria and the United Arab Emirates was signed that will introduce a 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 United Arab Emirates:
any entity the capital of which is wholly owned directly or indirectly, by the United Arab Emirates, by the federal or local government, a political subdivision, or a local authority thereof, as shall be exchanged from time to time between the Contracting States through notifications by the competent authorities