Agreement between the Government of the United States of America and the Government of the United Arab Emirates to Improve International Tax Compliance and to Implement FATCA

Whereas, the Government of the United States of America and the Government of the United Arab Emirates (each, a 'Party,' and together, the 'Parties') desire to conclude an agreement to improve international tax compliance;

Whereas, the United States of America enacted provisions commonly known as the Foreign Account Tax Compliance Act ('FATCA'), which introduce a reporting regime for financial institutions with respect to certain accounts;

Whereas, the Government of the United Arab Emirates is supportive of the underlying policy goal of FATCA to improve tax compliance;

Whereas, FATCA has raised a number of issues, including that United Arab Emirates financial institutions may not be able to comply with certain aspects of FATCA due to domestic legal impediments;

Whereas, the Parties are committed to working together over the longer term towards achieving common reporting and due diligence standards for financial institutions;

Whereas, the Government of the United States of America acknowledges the need to coordinate the reporting obligations under FATCA with other U.S. tax reporting obligations of United Arab Emirates financial institutions to avoid duplicative reporting;

Whereas, an intergovernmental approach to FATCA implementation would address legal impediments and reduce burdens for United Arab Emirates financial institutions;

Whereas, the Parties desire to conclude an agreement to improve international tax compliance and provide for the implementation of FATCA based on domestic reporting and automatic exchange, subject to the confidentiality and other protections provided for herein, including the provisions limiting the use of the information exchanged;

Now, therefore, the Parties have agreed as follows: