The Government of the Russian Federation and the Government of the United Arab Emirates,
Desiring to further develop their economic relationship and to enhance their cooperation in tax matters,
Intending to conclude an Agreement for the elimination of double taxation with respect to taxes on income and on capital and the prevention of tax evasion and avoidance 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).
Have agreed as follows:
1. This Agreement shall apply to persons who are residents of one or both of the Contracting States.
2. For the purposes ofthis Agreement, income derived by or through an entity or arrangement that is treated as wholly or partly fiscally tr...