Portugal–UAE treaty Preamble: Title and preamble

CONVENTION BETWEEN THE PORTUGUESE REPUBLIC AND THE UNITED ARAB EMIRATES FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME.

CONVENÇÃO ENTRE A REPÚBLICA PORTUGUESA E OS EMIRADOS ÁRABES UNIDOS PARA EVITAR A DUPLA TRIBUTAÇÃO E PREVENIR A EVASÃO FISCAL EM MATÉRIA DE IMPOSTOS SOBRE O RENDIMENTO.

The Portuguese Republic and the United Arab Emirates, desiring to promote their mutual economic relations through the conclusion between them of a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, have agreed as follows:

A República Portuguesa e os Emirados Árabes Unidos, desejando promover as suas relações económicas recíprocas através da celebração de uma convenção para evitar a dupla tributação e prevenir a evasão fiscal em matéria de impostos sobre o rendimento, acordam no seguinte:

Editorial note

Modified by Article 6(1) of the MLI (purpose of a covered tax agreement), with effect from 1 January 2021 for taxes withheld at source and for taxable periods beginning on or after 1 December 2020 for other taxes. Both States notified the second paragraph of this preamble ('desiring to promote their mutual economic relations through the conclusion between them of a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income') as preamble language described in MLI Art. 6(2). That language is therefore replaced by the MLI text: 'Intending to eliminate double taxation with respect to the taxes covered by this agreement without creating opportunities for non-taxation or reduced taxation through tax evasion or avoidance (including through treaty-shopping arrangements aimed at obtaining reliefs provided in this agreement for the indirect benefit of residents of third jurisdictions)'. The optional preamble wording in MLI Art. 6(3) does not apply: the UAE chose it, but Portugal did not. Source: MLI positions of Portugal (Decreto do Presidente da República n.º 70/2019, deposited 28 February 2020) and of the United Arab Emirates (deposited 29 May 2019); no synthesised text for this Convention has been published by either State as far as could be found.

Paying or receiving income between Portugal and the United Arab Emirates? Preamble may decide where it is taxed.

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The English column is an authentic text of the Convention, reproduced from the Diário da República publication (Resolution of the Assembly of the Republic No. 47/2012). The Convention was done in Portuguese, Arabic and English, each text being authentic; the English text prevails in case of divergence. The Portuguese text is reproduced from the official publication. Editorial notes are ours and are not part of the Convention.

Preamble Title and preamble

Treaty relief between Portugal and the United Arab Emirates, claimed correctly