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This agreement avoids double taxation and tax avoidance. Covered taxes under Article 2 are, for the UAE: the income tax and corporate tax; for South Sudan: the Personal Income Tax and Business Profits Tax. Domestic laws govern hydrocarbon income (Article 3). Per Articles 11, 12, and 13, dividends, interest, and royalties are taxable only in the recipient's state (implying a 0% withholding tax in the source state). Directors' fees are taxable only in the director's state of residence (Article 17). Both states apply the credit method for elimination of double taxation (Article 24).

Agreement Between The Government of UNITED ARAB EMIRATES And The Government of REPUBLIC OF SOUTH SUDAN For The Avoidance of Double Taxation and The Prevention of Fiscal Evasion With Respect To Taxes On Income

StatusNot Yet In Force

Signed on23 April 2019

Entered into force-

Amended on-

Terminated on-

Preamble

The Government of the United Arab Emirates and the Government of the Republic of South Sudan

Desiring to promote their mutual economic relations through the conclusion between them of an Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income;

Intending to conclude an Agreement for the elimination of double taxation with respect to taxes on income 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 States)

Have agreed as follows:

Contents

Article 1 - Personal Scope

Article 2 - Taxes Covered

Article 3 - Income from Hydrocarbons

Article 4 - General Definition

Article 5 - Resident

Article 6 - Permanent Establishment

Article 7 - Income from Immovable Property

Article 8 - Business Profits

Article 9 - Shipping and Air Transport

Article 10 - Associated Enterprises

Article 11 - Dividends

Article 12 - Interest

Article 13 - Royalties

Article 14 - Capital Gains

Article 15 - Independent Personal Services

Article 16 - Income from Dependent Personal Services

Article 17 - Directors’ Fees

Article 18 - Artists and Sportsmen

Article 19 - Pensions and Annuities

Article 20 - Government Service

Article 21 - Teachers and Researchers

Article 22 - Students and Trainees

Article 23 - Other Income

Article 24 - Elimination of Double Taxation

Article 25 - Mutual Agreement Procedure

Article 26 - Exchange of Information

Article 27 - Non-Discrimination

Article 28 - Miscellaneous Rules

Article 29 - Income of Government and Institutions

Article 30 - Members of Diplomatic Missions and Consular Posts

Article 31 - Entry into Force

Article 32 - Duration and Termination

Article 1Personal Scope

Article 1
Personal Scope