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:

• 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;

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