United Arab Emirates – Austria Protocol introduces dividend tax exemption for sovereign wealth funds

United Arab Emirates – Austria Protocol introduces dividend tax exemption for sovereign wealth funds

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.

https://www.parlament.gv.at/PAKT/VHG/XXVII/I/I_01030/imfname_994455.pdf

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

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