Article 1
People Included

This Convention applies to persons who are residents of one or both of the Contracting States.

Article 2
Taxes Included

1. This Convention shall apply to taxes on income and capital imposed by each Contracting State, its political subdivisions or local authorities, irrespective of the manner in which they are levied.

2. Taxes on income and on capital are considered to be those taxes levied on all income or capital or any part thereof, including taxes on gains from the alienation of movable or immovable property and taxes on the total amounts of wages or salaries paid by enterprises.

3. The current taxes to which this Convention applies are, in particular:

   1. In the case of the United Arab Emirates ('UAE'):

      1. income tax; and

      2. corporate tax.

      (hereinafter referred to as 'UAE Tax')

   2. In the case of Uruguay:

      1. the Tax on Income from Economic Activities (IRAE);

      2. the Personal Income Tax (IRPF);

      3. the Non-Resident Income Tax (IRNR);

      4. the Social Security Assistance Tax (IASS); and

      5. the Wealth Tax (IP);

      ('hereinafter referred to as the Uruguayan tax').

4. This Convention shall also apply to taxes of an identical or similar nature which are imposed under the laws of a Contracting State after the date of signature of this Convention and which are additional to or in place of the existing taxes. The competent authorities of the Contracting States shall notify each other of any significant changes made to their respective tax laws.

Article 3
General Definitions

1. For the purposes of this Convention, unless the context otherwise requires:

   1. The expression 'United Arab Emirates' when used in a geographical sense, means the territory of the United Arab Emirates that is under its sovereignty, as well as the area outside its waters territorial, airspace and submarine areas over which the United Arab Emirates exercise sovereign rights and jurisdictional, with respect to any activity carried out in its waters, seabed, subsoil, in relation to the exploration or exploitation of natural resources under its legislation and the international right.

   2. The term 'Uruguay' means the Eastern Republic of Uruguay, and when used in a geographical sense it means the territory in which that tax laws apply, including airspace, maritime areas, under Uruguayan jurisdiction or in which they are exercised sovereign rights, in accordance with international law and the national legislation;

   3. the expressions 'a Contracting State' and 'the other Contracting State' mean United Arab Emirates or Uruguay, depending on the context;

   4. the term 'person' includes natural persons, properties, partnerships, companies and any other another group of people;

   5. the term 'company' means any legal person or any entity that is considered a legal person for tax purposes;

   6. the term 'enterprise' applies to the exercise of any activity or business;

   7. a pension scheme means any plan, scheme, fund, trust or other arrangement established in a Contracting State, which is generally exempt from taxes in that State and operated mainly to administer or provide pensions or benefits of retirement or to obtain income for the benefit of one or more of such agreements.

   8. the expressions 'enterprise of a Contracting State' and 'enterprise of the other Contracting State' means, respectively, an enterprise operated by a resident of a Contracting State and an enterprise carried on by a resident of the other Contracting State;

   9. the expression 'international traffic' means all transport carried out by a vessel or aircraft operated by a company of a Contracting State, except when the ship or aircraft is operated only between points situated in the other Contracting State;

   10. the expression 'competent authority' means:

       1. in the case of the UAE: the Minister of Finance or a representative authorized by the Minister of Finance,

       2. in the case of Uruguay, the Ministry of Economy and Finance or its Authorized representative;

   11. the term 'national', in relation to a Contracting State, means:

       1. any natural person who possesses the nationality or citizenship of a Contracting State; and

       2. any legal person, partnership or association or other entity constituted under the law in force in a Contracting State or in its political subdivisions or local authorities.

   12. the term 'business' includes the exercise of professional services and the performance of other independent activities.

2. For the purposes of this Convention, any term or expression not defined in this Convention shall, unless the context otherwise requires, have the meaning which it has at that time under the laws of that Contracting State relating to the taxes to which this Convention applies, the meaning given to it by that tax law prevailing over any meaning given to it by other laws of that State.

Article 4
Resident
[GTL Notes - See Protocol 2]

1. For the purposes of this Convention, the term 'resident of a Contracting State' means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of management or any other criterion of a similar nature, including also that State and its political subdivisions or local authorities. This term does not, however, include persons who are liable to tax in that State solely on income derived from sources situated in that State or on capital situated therein.

2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows:

   1. such person shall be deemed to be a resident only of the State Contractor where he has a permanent home at his disposal; if had permanent housing available to him in both States Contracting parties shall be considered residents only of the State Contractor with whom you maintain personal and economic relations narrow (center of vital interests);

   2. if the Contracting State in which such a claim is made cannot be determined. person has the center of his vital interests or if he did not have one permanent housing available to them in any of the States Contracting parties shall be considered residents only of the State Contractor where he/she normally lives;

   3. if he habitually resides in both Contracting States, or does not did in any of them, will be considered a resident only of the Contracting State of which he/she is a national;

   4. if he is a national of both States, or is not a national of either of them, The competent authorities of the Contracting States shall resolve the case of mutual agreement.

3. Where by reason of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then it shall be deemed to be a resident only of the Contracting State in which its place of effective management is situated.

Article 5
Permanent Establishment

1. For the purposes of this Convention, the term 'permanent establishment' means a fixed place of business through which an enterprise carries on all or part of its business.

2. The term 'permanent establishment' includes, in particular:

   1. the management headquarters;

   2. branches;

   3. offices;

   4. factories;

   5. the workshops; and

   6. mines, oil or gas wells, quarries or any other place of exploration, extraction or exploitation of natural resources, or any activity related to them including offshore drilling sites.

3. The term 'permanent establishment' also includes:

   1. a construction or installation or assembly project or the inspection activities related to them or a platform drilling rig or a vessel used for exploration or exploitation of natural resources constitutes a permanent establishment only if such site, project or activities continue for a period greater than 183 days;

   2. the provision of services by an enterprise of a Contracting State through its employees or other personnel contracted by the company for such purpose, in the other Contracting State, but only if activities of that nature continue (in relation to the same or a related project) in that other Contracting State for a period or periods which in the aggregate exceed 183 days within any twelve-month period;

   3. for a natural person, the provision of services in a Contracting State by that natural person, but only if the stay of the natural person in that State is for a period or periods that in total exceed 183 days, within any period of twelve months.

4. Notwithstanding the preceding provisions of this Article, the term 'permanent establishment' shall be deemed not to include:

   1. the use of facilities for the sole purpose of storing or displaying goods or merchandise belonging to the company;

   2. the maintenance of a warehouse of goods or merchandise belonging to the company for the sole purpose of storing or displaying them;

   3. the maintenance of a warehouse of goods or merchandise belonging to the company with the sole purpose of being transformed by another company;

   4. the maintenance of a fixed place of business for the sole purpose of purchasing goods or merchandise or collecting information for the company.

5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 7 applies - acts in a Contracting State on behalf of an enterprise of the other Contracting State, that enterprise shall be deemed to have a permanent establishment in the first-mentioned Contracting State in respect of activities which that person performs for the enterprise, if that person:

   1. holds and habitually exercises in the first-mentioned Contracting State powers that enable it to conclude contracts in name of the company, unless that person's activities are limited to those mentioned in section 4 and that, if they had been carried out through a fixed place of business, would not have determined the consideration of said fixed place of business as a permanent establishment in accordance with the provisions of that section;

   2. does not hold such powers, but habitually maintains in the first-mentioned Contracting State a deposit of goods or merchandise belonging to said company from which he regularly delivers goods or merchandise on behalf of the company;

   3. habitually performs assignments in the first-mentioned Contracting State, exclusively or almost exclusively for the company itself, or for such company and other companies, which are controlled by it or who have a controlling interest in it; or

   4. within the framework of such activities, manufactures or transforms for the company, in that Contracting State, goods or merchandise belonging to the enterprise.

6. Notwithstanding the preceding provisions of this Article, an insurance enterprise of a Contracting State shall, except in respect of reinsurance, be deemed to have a permanent establishment in the other Contracting State if it collects premiums in the territory of that State or insures risks situated therein through a person other than an independent representative to whom paragraph 7 applies.

7. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. However, where the activities of such agent are carried on exclusively or almost exclusively for the account of that enterprise, and the terms entered into or imposed between the enterprise and the agent in their commercial and financial relations are different from those between independent enterprises, then that agent shall not be deemed to be an agent of an independent status within the meaning of this paragraph.

8. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State or which carries on business in that other Contracting State (whether through a permanent establishment or otherwise) shall not of itself constitute either company a permanent establishment of the other.

Article 6
Real Estate Income

1. Income derived by a resident of a Contracting State from immovable property (including income from agriculture or forestry) situated in the other Contracting State may be taxed in that other State.

2. The term 'immovable property' shall have the meaning it has under the law of the Contracting State in which the property in question is situated. It shall in all cases include property accessory to immovable property, livestock and equipment used in agricultural and forestry operations, rights to which the provisions of private law relating to real property are applicable, the usufruct of immovable property and the right to receive fixed or variable payments in return for the exploitation, or the concession to exploit, mineral deposits, springs and other natural resources; ships and aircraft shall not be considered as immovable property.

3. The provisions of paragraph 1 shall apply to income derived from the direct use, leasing or sharecropping, as well as from any other form of exploitation of real estate.

4. The provisions of paragraphs 1 and 3 shall also apply to income derived from the real estate property of an enterprise.

Article 7
Business Net Income

1. The profits of an enterprise of a Contracting State shall be taxable only in that Contracting State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated therein. In such case, such profits may be taxed in the other Contracting State but only so much as is attributable to: a) such permanent establishment, b) sales in that other State of goods or merchandise of an identical or similar kind to those sold through such permanent establishment, or c) other business activities carried on in that other State of an identical or similar kind to those carried on through such permanent establishment.

2. Notwithstanding the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establishment situated therein, there shall in each Contracting State be attributed to such permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment.

3. In determining the profits of the permanent establishment, there shall be allowed as deductions expenses incurred for the purposes of the permanent establishment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere.

4. Profits shall not be attributed to a permanent establishment for the mere purchase of goods or merchandise for the enterprise.

5. Insofar as it may be customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph 2 shall prevent that Contracting State from determining its taxable profits in such a manner; however, the method of apportionment adopted must be such that the result obtained is in conformity with the principles contained in this Article.

6. For the purposes of the preceding paragraphs, the profits attributable to the permanent establishment shall be calculated each year using the same method, unless there are valid and sufficient reasons to proceed otherwise.

7. Where profits include elements of income regulated separately in other Articles of this Convention, the provisions of those Articles shall not be affected by the provisions of this Article.

Article 8
Maritime and Air Navigation[GTL Notes - See Protocol 3]

Notwithstanding the provisions of Article 7 of this Convention:

1. The profits of an enterprise of a Contracting State derived from the operation of ships or aircraft in international traffic may be taxed only in that State.

2. For the purposes of this Article, profits derived from the operation of ships or aircraft in international traffic include:

   1. profits resulting from the leasing of ships or aircraft by hull naked;

   2. profits derived from the use, maintenance or leasing of containers, including trailers and related equipment Container transport, used for the transport of goods and goods;

   when such leasing, use or maintenance, as applicable, is accessory to the operation of ships or aircraft in international traffic.

3. The provisions of paragraph 1 shall also apply to profits derived from:

   1. participation in a consortium -pool-, in a joint venture or in a international exploitation agency;

   2. the sale of tickets on behalf of another company;

   3. income from the sale of technical engineering to other companies transport companies; or

   4. income derived from bank deposits, bonds, stocks, securities and Other debentures directly linked to the operation of ships or aircraft in international traffic, if they are an integral part from the development of said activity.

Article 9
Affiliates

1. When

   1. an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of a company of the other Contracting State, or

   2. the same persons participate directly or indirectly in the management, control or capital of a state enterprise

   Contracting State and a company of the other Contracting State, and, in one and otherwise, the two companies are, in their commercial relations or financial, united by accepted or imposed conditions that differ of those that would be agreed upon by independent companies, the profits that would have been obtained by one of the companies if not such conditions exist, and that in fact they have not been realized because of the same, may be included in the profits of that company and be taxed accordingly.

2. Where a Contracting State includes in the profits of an enterprise of that Contracting State - and consequently taxes - the profits of an enterprise of the other Contracting State which have already been taxed by that second Contracting State, and the profits so included are those which would have been realised by the enterprise of the first-mentioned Contracting State if the terms agreed between the two enterprises had been those agreed between independent enterprises, that other Contracting State shall make an appropriate adjustment to the amount of tax which it has levied on such profits. In determining such adjustment, regard shall be had to the other provisions of this Convention and the competent authorities of the Contracting States shall consult each other if necessary.

Article 10
Dividends[GTL Notes - See Protocol 4]

1. Dividends paid by a company which is a resident of a Contracting State to a resident of the other Contracting State may be taxed in that other State.

2. However, such dividends may also be taxed in the Contracting State in which the company paying the dividends is resident and according to the laws of that State, but if the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed:

   1. 5 percent of the gross amount of dividends if the beneficial owner is a company (other than a partnership) or a government institution listed in Article 11, paragraph 3; or

   2. 7 percent of the gross amount of dividends in other cases.

   This section does not affect the company's taxation of the profits from which the dividends are paid.

3. The term 'dividends' as used in this Article means income from shares, shares or debentures, mining interests, founders' shares or other rights, other than credit rights, which permit participation in profits, as well as income from other company interests subject to the same tax treatment as income from shares under the tax laws of the Contracting State in which the company making the distribution is resident.

4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the dividends, being a resident of a Contracting State, carries on business in the other Contracting State of which the company paying the dividends is a resident, through a permanent establishment situated therein, and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment. In such case, the provisions of Article 7 shall apply.

5. Where a company which is a resident of a Contracting State derives profits or income from the other Contracting State, that other Contracting State may not impose any tax on the dividends paid by the company, except insofar as such dividends are paid to a resident of that other Contracting State or the holding in respect of which the dividends are paid is effectively connected with a permanent establishment situated in that other Contracting State, nor subject the company's undistributed profits to any tax thereon, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in that other Contracting State.

Article 11
Interest

1. Interest arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State.

2. However, such interest may also be taxed in the Contracting State in which it arises and according to the laws of that State, but if the beneficial owner of the interest is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the interest.

3. Notwithstanding the provisions of the preceding paragraphs, interest arising in a Contracting State and paid to a resident of the other Contracting State may be taxed only in that other State if:

   1. the beneficial owner of the interest is the Government, a political subdivision or a local authority, or the Central Bank of the another Contracting State;

   2. the interest is paid by any of the entities mentioned in section a);

   3. in the case of the UAE, the beneficial owner of the interest is one of the following entities as long as they are wholly owned by UAE:

      1. The Abu Dhabi Investment Authority;

      2. The Abu Dhabi Investment Council;

      3. Mubadala Development Company (Mubadala);

      4. Dubai World;

      5. Investment Corporation of Dubai;

      6. Emirates Investment Authority;

      7. International Petroleum Investment Company (IPIC);

      8. Abu Dhabi National Energy Company (TAQA); and

      9. any other government entity that may be specified in accordance with domestic legislation, which may be agreed upon any time between the competent authorities of the Contracting States; and

   4. in the case of Uruguay, the effective beneficiary of the interests is one of the following entities as long as they are wholly owned by Uruguay:

      1. Central Bank of Uruguay;

      2. Bank of the Oriental Republic of Uruguay;

      3. Mortgage Bank of Uruguay;

      4. National Development Corporation; and

      5. any other governmental entity that may be specified in accordance with domestic legislation, which may be agreed at any time moment between the competent authorities of the Contracting States.

4. The term 'interest' as used in this Article means income from debt-claims of every kind, whether or not secured by mortgage or without a provision for participation in the debtor's profits, and in particular income from government securities and income from bonds and debentures, including premiums and prizes attaching to such securities. Penalties for late payment shall not be considered as interest for the purposes of this Article.

5. The provisions of paragraphs 1, 2 and 3 shall not apply if the beneficial owner of the interest, being a resident of a Contracting State, carries on business in the other Contracting State in which the interest arises through a permanent establishment situated therein and the debt-claim in respect of which the interest is paid is effectively connected with such permanent establishment. In such case, the provisions of Article 7 shall apply.

6. Interest shall be deemed to arise in a Contracting State when the payer is a resident of that Contracting State. Where, however, the payer of the interest, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the indebtedness on which the interest is paid was incurred, and such interest is borne by such permanent establishment, then such interest shall be deemed to arise in the Contracting State in which the permanent establishment is situated.

7. Where, by reason of a special relationship between the debtor and the beneficial owner or between both of them and some other person, the amount of interest, having regard to the debt claim in respect of which it is paid, exceeds the amount which would have been agreed upon by the debtor and the creditor in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess amount may be taxed according to the laws of each Contracting State, having regard to the other provisions of this Convention.

Article 12
Royalties and Fees for Technical Services

1. Royalties or fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State.

2. However, such royalties or fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the beneficial owner of the royalties or fees for technical services is a resident of the other Contracting State, the tax so charged shall not exceed:

   1. 0 percent of the gross amount of royalties or fees for technical services related to exploration, extraction or exploitation of hydrocarbons, paid for by institutions Governments of one of the Contracting States to institutions governmental bodies of the other Contracting State;

   2. 5 percent of the gross amount of royalties, in the case of payments for the use or the right to use industrial, commercial or scientists; and

   3. 10 percent of the gross amount of royalties or fees for technical services, in all other cases.

3. (a) The term 'royalties' as used in this Article means amounts of any kind paid for the use of, or the right to use, copyright in literary, artistic or scientific works, including cinematographic films and films or tapes for broadcast on television or radio, for patents, trademarks, designs or models, plans, secret formulas or processes, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information relating to industrial, commercial or scientific experience.

   (b) The term 'fees for technical services' as used in this Article means payments of any kind in consideration for any service of a technical, administrative or consulting nature.

4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties or technical services fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or technical services fees arise, through a permanent establishment situated therein, and the good, right or service in respect of which the royalties or technical services fees are paid is effectively connected with such permanent establishment. In such case the provisions of Article 7 shall apply.

5. Royalties and technical services fees shall be deemed to arise in a Contracting State when the payer is a resident of that Contracting State. Where, however, the payer of the royalties or technical services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the liability to pay the royalties or technical services was incurred, and such royalties or technical services fees are borne by such permanent establishment, then such royalties or technical services fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated.

6. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of any royalties or fees for technical services, having regard to the use, right, information or service for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case the excess amount may be taxed according to the laws of each Contracting State, taking into account the other provisions of this Convention.

Article 13
Capital Gains

1. Gains derived by a resident of a Contracting State from the alienation of immovable property as defined in Article 6 situated in the other Contracting State may be taxed in that other State.

2. Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State, including gains from the alienation of such permanent establishment (alone or with the whole enterprise), may be taxed in that other State.

3. Gains from the alienation of ships or aircraft operated in international traffic, or of movable property pertaining to the operation of such ships or aircraft, may be taxed only in the Contracting State of which the alienator is a resident.

4. Gains derived by a resident of a Contracting State from the alienation of shares or other interests in a company or trust, more than 50% of the value of which is derived, directly or indirectly, from real property situated in the other Contracting State, may be taxed in that other State. [GTL Notes - See Protocol 5]

5. Gains from the alienation of any property other than those mentioned in the preceding paragraphs may be taxed only in the Contracting State in which the alienator is a resident. [GTL Notes - See Protocol 6]

Article 14
Income from Employment

1. Notwithstanding the provisions of Articles 15, 17 and 18, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of dependent employment shall be taxable only in that Contracting State unless the dependent employment is exercised in the other Contracting State. If the dependent employment is exercised in the latter State, the remuneration derived therefrom may be taxed in that other Contracting State.

2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment performed in the other Contracting State may be taxed only in the first-mentioned State if:

   1. the recipient remains in the other State for a period or periods whose duration does not exceed, in total, 183 days in any period of twelve months beginning or ending in the fiscal year under consideration, and

   2. the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State, and

   3. the remunerations are not borne by a permanent establishment that the employer has in the other State.

3. Notwithstanding the preceding provisions of this Article, remuneration derived from dependent employment performed on board a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed only in that Contracting State. This paragraph shall not apply if the employee is a resident or a national of the other Contracting State.

Article 15
Directors Fees

Directors' fees and other similar payments derived by a resident of a Contracting State as a member of the board of directors or the supervisory board of a company which is a resident of the other Contracting State may be taxed in that other State.

Article 16
Artists and Athletes

1. Notwithstanding the provisions of Articles 7 and 14, income derived by a resident of a Contracting State as an entertainer, such as a theatre, motion picture, radio or television artiste, or a musician, or as a sportsman, from his personal activities as such exercised in the other Contracting State, may be taxed in that other State.

2. Notwithstanding the provisions of Articles 7 and 14, where income derived from the personal activities of entertainers or athletes in that capacity accrues not to the entertainer or athlete himself but to another person, that income may be taxed in the Contracting State in which the activities of the entertainer or athlete are performed.

Article 17
Pensions

Notwithstanding the provisions of paragraph 2 of Article 18, pensions and other similar remuneration paid to a resident of a Contracting State in respect of previous dependent employment may be taxed only in that State.

Article 18
Government Service

1. 1. Salaries, wages and other similar remunerations paid by a Contracting State or one of its political subdivisions or local authorities to a natural person for services rendered to that State or that subdivision or authority, can only be subject to taxation in that State.

   2. However, such salaries, wages and remunerations may only be subject to taxation in the other Contracting State if the services are provided in that State and the natural person is a resident of that State who:

      1. is a national of that State, or

      2. has not acquired the status of resident of that State only to provide the services.

2. 1. Notwithstanding the provisions of paragraph 1, pensions and other similar remuneration paid by a Contracting State or by one of its political subdivisions or local authorities, either directly or from funds established by them, to a natural person for services rendered to that State or to that subdivision or authority, may only be subject to taxation in that State.

   2. However, such pensions and other similar remunerations only may be taxed in the other Contracting State if the natural person is a resident and national of that State.

3. The provisions of Articles 14, 15, 16 and 17 shall apply to salaries, wages, pensions and other similar remuneration paid for services rendered in the framework of an activity or business carried on by a Contracting State or a political subdivision or local authority thereof.

Article 19
Students

Amounts received for the purpose of his maintenance, education or training by a student or apprentice who is, or was immediately before visiting a Contracting State, a resident of the other Contracting State and who is present in the first-mentioned State solely for the purpose of his education or training, shall not be taxed in that State provided that such amounts arise from sources outside that State.

Article 20
Other Income

1. Income of a resident of a Contracting State, whatever its source, not mentioned in the previous Articles of this Convention may be taxed only in that State.

2. The provisions of paragraph 1 shall not apply to income, other than income from immovable property within the meaning of paragraph 2 of Article 6, if the recipient of such income, being a resident of a Contracting State, carries on business in the other Contracting State through a permanent establishment situated therein, and the right or property in respect of which the income is paid is effectively connected with such permanent establishment. In such case, the provisions of Article 7 shall apply.

3. The provisions of paragraph 2 shall not apply to cases where the agreement between the parent companies and the permanent establishments has been made for the primary purpose of taking advantage of this provision of paragraph 2.

4. Notwithstanding the provisions of paragraphs 1 and 2, income of a resident of a Contracting State not mentioned in the preceding Articles and arising in the other Contracting State may also be taxed in that other State.

Article 21
Capital

1. The capital assets of a resident of a Contracting State may be taxed in that State.

2. However, capital assets situated in the other Contracting State may also be taxed in that other State.

3. Notwithstanding the provisions of paragraphs 1 and 2, capital consisting of movable property forming part of the business assets of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State may be taxed in that other State.

4. Notwithstanding the provisions of paragraphs 1 and 2, assets consisting of ships and aircraft operated in international traffic and movable property pertaining to the operation of such ships or aircraft may be taxed only in the Contracting State in which the enterprise owning such assets is resident.

Article 22
Elimination of Double Taxation

Double taxation shall be eliminated in the Contracting States as follows:

1. Where a resident of a Contracting State derives income or owns capital which, in accordance with the provisions of this Convention, may be taxed in the other Contracting State, the first-mentioned State shall allow:

   1. the deduction in the income tax of that resident, of an amount equal to the income tax paid in that other State;

   2. the deduction in the wealth tax of that resident, of an amount equal to the wealth tax paid in that other State.

   In either case, such deduction may not, however, exceed the part of the income or capital tax calculated before the deduction, corresponding, as the case may be, to the income or capital that may be subject to taxation in that other State.

2. Where, in accordance with any provision of this Convention, income derived by a resident of a Contracting State or capital owned by him is exempt from tax in that State, that State may nevertheless take into account the exempt income or capital in calculating the tax on the remaining income or capital of that resident.

Article 23
Non Discrimination

1. Nationals of a Contracting State shall not be subjected in the other Contracting State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which nationals of that other State in the same circumstances, in particular with respect to residence, are or may be subjected. Notwithstanding the provisions of Article 1, this provision shall also apply to persons who are not residents of one or both of the Contracting States.

2. Permanent establishments which an enterprise of a Contracting State has in the other Contracting State shall not be subjected to taxation in that State in a less favourable manner than enterprises of that other State carrying on the same activities. This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents.

3. Unless the provisions of paragraph 1 of Article 9, paragraph 6 of Article 11 or paragraph 6 of Article 12 apply, interest, royalties and other disbursements paid by an enterprise of a Contracting State to a resident of the other Contracting State shall be deductible, for the purposes of determining the taxable profits of such enterprise, under the same conditions as if they had been paid to a resident of the first-mentioned State. Likewise, debts of an enterprise of a Contracting State incurred by a resident of the other Contracting State shall be deductible, for the purposes of determining the taxable capital of such enterprise, under the same conditions as if they had been incurred by a resident of the first-mentioned State.

4. Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected.

5. In this Article the term 'tax' means taxes of whatever nature or designation covered by this Convention.

Article 24
Mutual Agreement Procedure

1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, independently of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 23, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the measure resulting in taxation not in accordance with the provisions of this Convention.

2. The competent authority shall, if the complaint appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, endeavour to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation not in accordance with this Convention. The agreement shall apply without regard to any time-limits provided for by the domestic law of the Contracting States.

3. The competent authorities of the Contracting States shall endeavour to resolve any difficulties or doubts arising as to the interpretation or application of this Convention by mutual agreement. They may also object by mutual agreement in order to try to eliminate double taxation in cases not provided for in this Convention.

4. In order to reach an agreement within the meaning of the preceding paragraphs, the competent authorities of the Contracting States may communicate directly, including within a joint commission composed of themselves or their representatives.

Article 25
Exchange of Information[GTL Notes - See Protocol 7]

1. The competent authorities of the Contracting States shall exchange information reasonably relevant for carrying out the provisions of this Convention or for administering and enforcing the provisions of the national laws of the Contracting States relating to taxes of every kind and nature levied by the Contracting States, their subdivisions or local authorities insofar as the taxation provided for herein is not contrary to the Convention. The exchange of information shall not be limited by Articles 1 and 2.

2. Information received by a Contracting State under paragraph 1 shall be treated as secret in the same manner as information obtained under the domestic laws of that State and shall be disclosed only to persons or authorities (including courts and administrative bodies) engaged in the assessment or collection of, the effective enforcement or prosecution of non-compliance with, the determination of appeals in relation to, or the supervision of the foregoing functions of, the taxes referred to in paragraph 1. Such persons or authorities shall use this information only for these purposes. They may disclose the information in open court proceedings or in judicial decisions.

3. In no case shall the provisions of paragraphs 1 and 2 be construed so as to oblige a Contracting State:

   1. adopt administrative measures contrary to its laws or practices administrative, or those of the other Contracting State;

   2. provide information that cannot be obtained on the basis of your its own legislation or in the exercise of its administrative practice normal, or those of the other Contracting State;

   3. provide information that reveals trade secrets, management secrets, industrial or professional, commercial or information whose communication is contrary to public order.

4. If a Contracting State requests information under this Article, the other Contracting State shall use its information gathering measures to obtain the requested information, even though that other State may not need the information for its own tax purposes. The foregoing obligation is limited by paragraph 3 provided that this paragraph is not construed to prevent a Contracting State from providing information solely because of the absence of a domestic interest in the information.

5. In no case shall the provisions of paragraph 3 be construed to permit a Contracting State to refuse to provide information solely because it is held by banks, other financial institutions, or any person acting in an agent or fiduciary capacity or because such information relates to the ownership interest of a person.

Article 26
Miscellaneous Rules

The provisions of this Agreement shall not be construed to restrict in any way any exclusion, exemption, deduction, credit or other allowance now or hereafter granted:

1. by the laws of a Contracting State regarding the determination of the taxes imposed by that Contracting State; or

2. by any other special tax agreement between the Contracting States or between one of the Contracting States and residents of the another Contracting State.

Article 27
Members of Diplomatic Missions and Consular Offices

The provisions of this Convention shall not affect the tax privileges enjoyed by members of diplomatic missions or consular offices in accordance with the general principles of international law or under the provisions of special agreements.

Article 28
Entry into Force

1. Each Contracting State shall notify the other that the legal requirements for the entry into force of this Convention have been met.

2. The Convention shall enter into force fifteen days after the date of receipt of the last notification referred to in paragraph 1 and its provisions shall take effect:

   1. with respect to taxes withheld at source, to the amounts paid or credited from the first day of January, inclusive, of the calendar year following the one in which this Agreement comes into force.

   2. with respect to the remaining taxes, to the tax periods that start from the first day of January, inclusive, of the calendar year following the one in which this Agreement comes into force.

3. Without prejudice to the provisions of paragraph 2, Article 25 shall take effect on the day of its entry into force, but only in respect of taxable periods beginning on or after that date, or in cases where there are no taxable periods, in respect of taxable events occurring on or after that date.

Article 29
Termination

This Agreement shall remain in force until terminated by one of the Contracting States. Either Contracting State may terminate the Agreement by diplomatic means by giving notice at least six months prior to the end of any calendar year following the fifth year after its entry into force. In such event, the Agreement shall cease to apply:

1. with respect to taxes withheld at source, to the amounts paid or credited from the first day of January, inclusive, of the calendar year following that in which the termination is communicated; and

2. with respect to the remaining taxes, to the tax periods that start from the first day of January, inclusive, of the calendar year following that in which the termination is communicated.

IN WITNESS WHEREOF, the signatories, being duly authorized to that effect by their respective Governments, have signed this Convention.

Done at Washington on 10 October 2014, in duplicate, in the Spanish, Arabic and English languages. In the event of any discrepancies between the texts, the English version shall prevail.

PROTOCOL

At the time of signing this Agreement between the United Arab Emirates and the Eastern Republic of Uruguay for the avoidance of double taxation and the prevention of tax evasion with respect to taxes on income and capital (hereinafter referred to as the Agreement), the undersigned have agreed to the following provisions which form an integral part of the Agreement.

1. With regard to the entire Convention Notwithstanding any other provision of this Agreement, nothing shall affect the right of any of the Contracting States, or any of their local governments or local authorities, to apply its internal rules and regulations relating to the taxation of income and profits derived from hydrocarbons and their related activities situated in the territory of the respective Contracting State, as applicable.

2. Regarding Article 4

   With regard to paragraph 1 of Article 4, the term 'resident' in the case of the UAE is understood to include:

   1. any natural person who is a national under the legislation of the United Arab Emirates or any of its political subdivisions or local authorities, provided that the natural person has a substantial presence, a permanent home or habitually living in the UAE and that the person's personal and economic relations physical relations are closer in the UAE than in any other state;

   2. any of the government entities listed in section 3 of Article 11; and

   3. any person other than a natural person (including pension schemes, charities or religious organizations, educational or cultural) that is established under the legislation of the United Arab Emirates or any of its political subdivisions or local governments.

3. Regarding Article 8

   Regarding Article 8, in Dubai on 5 July 2012, the Government of the United Arab Emirates and the Eastern Republic of Uruguay signed an Agreement on air services which is not yet in force.

   The provisions of this Convention regarding air transport shall apply without prejudice to the tax exemptions included in said Agreement.

4. Regarding Article 10

   With respect to Article 10, if after the entry into force of this Convention, Uruguay grants to a third country under a Convention or Protocol more favourable treatment than that granted to the UAE, such treatment shall automatically be granted to the UAE.

5. Regarding Article 13 paragraph 4

   The provisions of Article 13 paragraph 4 shall not apply to gains derived by a resident of a Contracting State if the shares or other comparable interests in an entity resident of the other Contracting State, more than 50% of whose value is derived directly or indirectly from immovable property situated in the other Contracting State, are listed on a recognised stock exchange. In such case, Article 13 paragraph 5 shall apply.

6. Regarding Article 13 paragraph 5

   For the purposes of interpreting Article 13, it is understood that capital gains included in paragraph 5, obtained by a resident of a Contracting State, including government financial institutions or investment companies, from the alienation of shares or comparable interests in a company, may be taxed only in the State in which these alienators reside.

7. Regarding Article 25

   It is understood that the administrative assistance provided for in Article 25 does not include measures aimed solely at the simple collection of evidence ('fishing expeditions').

IN WITNESS WHEREOF, the signatories, being duly authorized to that effect by their respective Governments, have signed this Protocol.

Done at Washington on 10 October 2014, in duplicate, in the Spanish, Arabic and English languages. In the event of any discrepancies between the texts, the English version shall prevail.