<h3>Tax Rates</h3><table><thead><tr><th>Item</th><th>Article reference</th><th>Applicable Rates</th><th>Comments</th></tr></thead><tbody><tr><td>Dividends</td><td>Article 10</td><td>5%</td><td>If the beneficial owner of the dividends is a resident of the other Contracting State.</td></tr><tr><td>Dividends</td><td>Article 10</td><td>0% (source state exemption)</td><td>If the beneficial owner is the other State itself, political subdivision, local Government, local authority, Central Bank thereof, recognized pension fund, Abu Dhabi Investment Authority, Abu Dhabi Investment Council, Emirates Investment Authority, Mubadala Development Company, International Petroleum Investment Company, Dubai World, Investment Corporation of Dubai, or any other institution created by the Government, a political subdivision, local authority or local Government of that other State which is recognized as an integral part of that Government as shall be agreed through exchange of letters.</td></tr><tr><td>Interest</td><td>Article 11</td><td>5%</td><td>If the beneficial owner of the interest is a resident of the other Contracting State.</td></tr><tr><td>Interest</td><td>Article 11</td><td>0% (source state exemption)</td><td>If the beneficial owner is the other State itself, political subdivision, local Government, local authority, Central Bank thereof, recognized pension fund, Abu Dhabi Investment Authority, Abu Dhabi Investment Council, Emirates Investment Authority, Mubadala Development Company, International Petroleum Investment Company, Dubai World, Investment Corporation of Dubai, or any other institution created by the Government, a political subdivision, local authority or local Government of that other State which is recognized as an integral part of that Government as shall be agreed through exchange of letters.</td></tr><tr><td>Interest</td><td>Article 11</td><td>0% (source state exemption)</td><td>Interest arising in United Arab Emirates and paid in consideration of a loan guaranteed or insured by SID Bank (SID Slovenska izvozna in razvojna banka) Inc., Ljubljana on account of the Republic of Slovenia as authorized in accordance with the domestic law shall be exempt from tax in United Arab Emirates.</td></tr><tr><td>Royalties</td><td>Article 12</td><td>5%</td><td>If the beneficial owner of the royalties is a resident of the other Contracting State.</td></tr><tr><td>Fees for Technical Services (FTS)</td><td>N/A</td><td>Not provided</td><td></td></tr><tr><td>Capital Gains : Immovable Property</td><td>Article 13(1)</td><td>May be taxed in source state</td><td>Gains derived from the alienation of immovable property situated in the other Contracting State.</td></tr><tr><td>Capital Gains : Shares</td><td>Article 13(4)</td><td>May be taxed in source state</td><td>Shares or comparable interest of any kind deriving more than 50 per cent of their value directly or indirectly from immovable property situated in the other Contracting State.</td></tr><tr><td>Capital Gains : Shares</td><td>Article 13(5) &amp; Protocol</td><td>0% (residence state only)</td><td>Gains from the alienation of any property other than those specifically referred to in paragraphs 1, 2, 3 and 4 of Article 13, including shares other than those dealt with in paragraph 4.</td></tr><tr><td>Construction PE</td><td>Article 5(3)</td><td>More than 9 months</td><td>Building site, construction, assembly or installation project or a supervisory or consultancy activity connected therewith, or drilling rig or ship used for the exploration or exploitation of natural resources.</td></tr><tr><td>Services PE</td><td>N/A</td><td>Not provided</td><td></td></tr></tbody></table><h3>Other Relevant Provisions</h3><table><thead><tr><th>Provision</th><th>Article reference</th><th>Description</th></tr></thead><tbody><tr><td>Hydrocarbons carve-out : preserves domestic hydrocarbon taxation rights</td><td>Protocol, Point 1</td><td>Nothing in this Agreement shall affect the right of either of the Contracting States or of any of their political subdivisions, local Governments or local authorities thereof to apply their domestic laws and regulations related to the taxation of income and profits derived from hydrocarbons and natural resources and its associated activities situated in the territory of the respective Contracting State.</td></tr><tr><td>Government / sovereign income exemption</td><td>Article 10(3), Article 11(3)</td><td>Dividends and interest may be taxable only in the other Contracting State if the beneficial owner is that other State itself, political subdivision, local Government, local authority, Central Bank thereof, recognized pension fund, or specific listed UAE entities (Abu Dhabi Investment Authority, etc.), or any other agreed governmental institution.</td></tr></tbody></table>