The Government of the Republic of South Africa and the Government of the United Arab Emirates desiring to promote and strengthen their economic relations
[MODIFIED by paragraph 1 and paragraph 3 of Article 6 of the MLI] [by concluding an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income,]
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The following paragraph 1 of Article 6 of the MLI replaces the text referring to an intent to eliminate double taxation in the preamble language of this Agreement: ARTICLE 6 OF THE MLI - PURPOSE OF A COVERED TAX AGREEMENT 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) |
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The following paragraph 3 of A... |