AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF INDONESIA AND THE GOVERNMENT OF THE UNITED ARAB EMIRATES FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME

The Government of the Republic of Indonesia and the Government of the United Arab Emirates,

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 residence of third jurisdictions).

Have agreed as follows:

ARTICLE 1 - PERSONAL SCOPE

1. This Agreement shall apply to persons who are residents of one or both of the Contracting States.

2. This Agreement shall not affect the taxation by Indonesia of its residents, except with respect to the benefits granted under paragraph 3 of Article 7, paragraph 2 of Article 9, or Article 17, Article 21, Article 23, Article 24, Article 25, or Article 27 of this Agreement.

ARTICLE 2 - TAXES COVERED

1. This Agreement shall apply to taxes on income imposed on behalf of a Contra...