This Convention shall apply to individuals and bodies corporate who are residents of one or both of the States 

1. The existing taxes to which the Convention shall apply are: 

a) In the case of the State of the United Arab Emirates: - any tax on the income of companies established in the United Arab Emirates; - any tax on total income or on elements of income - including gains from the alienation of movable or immovable property - and any inheritance tax which are imposed in the United Arab Emirates after the date of signature of the Convention and which are similar to those to which the Convention applies in the case of France; 
b) In the case of France: - the income tax; - the corporation tax; - the inheritance tax; including any withholding tax, prepayment (precomte) or advance payment with respect to the aforesaid taxes; (hereinafter referred to as "French tax"). 

3. The competent authorities of the two States shall notify each other of any substantial changes which have been made in their respective taxation laws. 

1. For the purposes of this Convention, unless the context otherwise requires: 

a) The terms "one State" and "the other State" mean, as appropriate, the State of the United Arab Emirates or the French Republic; 
b) The term "person" includes an individual or a company; 
c) The term "company" means any body corporate governed by public or private law, including, in the case of the United Arab Emirates, the State of the United Arab Emirates, its political subdivisions and local authorities, or any entity regarded as a body corporate for the purposes of taxation; 
d) The terms "enterprise of one State" and "enterprise of the other State" mean respectively an enterprise carried on by a resident of one State and an enterprise carried on by a resident of the other State; 
e) The term "international traffic" means: - any transport by a ship operated by an enterprise which has its place of effective management in one State, except when the ship is operated solely between places in the other State; - any transport by an aircraft operated by an enterprise of one State, except when the aircraft is operated solely between places in the other State; 
f) The term "competent authority" means: - in the case of the United Arab Emirates, the Minister of Finance or his authorized representative; - in the case of the French Republic, the Minister in charge of the Budget or his authorized representative. 

1. For the purposes of this Convention, the term "resident of one State" means: 

a) In the case of the United Arab Emirates, any person domiciled, established or having his place of management in the United Arab Emirates, including the State of the United Arab Emirates, its political subdivisions and local authorities; 
b) In the case of France, any person who, under the laws of France, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature. 

a) He shall be deemed to be a resident of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident of the State with which his personal and economic relations are closer (centre of vital interests); 
b) If the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident of the State in which he has an habitual abode; 
c) If he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident of the State of which he is a national; 
d) If he is a national of both States or of neither of them, the competent authorities of the two States shall settle the question by mutual agreement. 

1. Income derived by a resident of one State from immovable property (including income from agriculture or forestry) situated in the other State may be taxed in that other State. 

2. The term "immovable property" shall have the meaning which it has under the law of the State in which the property in question is situated. The term shall in any case include property accessory to immovable property, livestock and equipment used in agriculture and forestry, rights to which the provisions of general law respecting landed property apply and rights to variable or fixed payments as consideration for the working of, or the right to work, mineral deposits, sources and other natural resources; ships and aircraft shall not be regarded as immovable property. 

3. The provisions of paragraph 1 shall also apply to income derived from the direct use, letting or use in any other form of immovable property. 

4. Where the ownership of shares or other rights in a company or other body corporate gives the owner the right to enjoyment of immovable property situated in one State and owned by that company or other body corporate, the income which the owner of the shares or other rights derives from the direct use, letting or use in any other form of his right to such enjoyment shall be taxable in that State. 

1. The profits of an enterprise of one State shall be taxable only in that State unless the enterprise carries on business in the other State through a permanent establishment situated therein. If the enterprise carries on business as aforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. 

2. Income derived directly by a company resident in France from the marketing of oil and from oil-drilling rights in the United Arab Emirates shall be taxable in the United Arab Emirates in accordance with the tax laws promulgated by the State of the United Arab Emirates or by any Emirate of that State. 

3. The profits attributed to a permanent establishment are those which it might be expected to make if it were a distinct and separate establishment dealing wholly independently with the enterprise of which it is a permanent establishment. In the determination of such profits, there shall be allowed as a deduction the total amount of the expenses incurred either in the State in which the permanent establishment is situated or elsewhere. 

4. 
A. For the purposes of this Convention, the term permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 

B. The term "permanent establishment" includes especially: 

a) A place of management; 
b) A branch; 
c) An office; 
d) A factory; 
e) A workshop; and 
f) A mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 

D. Notwithstanding the preceding provisions of this article, the term "permanent establishment" shall be deemed not to include: 

a) The use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise;
b) The maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; 
c) The maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; 
d) The maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information for the enterprise; 
e) The maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; 
f) The maintenance of a fixed place of business solely for any combination of the activities mentioned in subparagraphs (a) to (e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. 

F. An enterprise shall not be deemed to have a permanent establishment in a State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. 

G. The fact that a company which is a resident of one State controls or is controlled by a company which is a resident of the other State or which carries on business in that other State (whether through a permanent establishment or otherwise) shall not of itself constitute either company a permanent establishment of the other. 

1. Income which an enterprise of the United Arab Emirates derives from the operation of aircraft in international traffic, including income accessory to such operation, shall be exempt in France from the taxes specified in Article 2 (paragraph 1(b)) of the Convention and, notwithstanding the provisions of that same article, from the business tax in respect of the portion corresponding to the share of the operation carried out by individuals resident in the United Arab Emirates or corresponding to the share of the capital of the enterprise held directly or indirectly either by individuals resident in the United Arab Emirates, or by joint stock companies or partnerships whose place of effective management is situated in the United Arab Emirates, or by the State of the United Arab Emirates or by companies in which that State holds shares. 

2. Income which an enterprise of France derives from the operation of aircraft in international traffic, including income accessory to such operation, shall be exempt in the United Arab Emirates from the taxes specified in Article 2 (paragraph 1(a)) and, notwithstanding the provisions of Article 2 of the Convention, from any tax identical to the business tax. 

3. Notwithstanding the provisions of Article 3, paragraph 1(a): 

a) For the purposes of paragraph 1 of this Article, the term "enterprise of the United Arab Emirates" means an enterprise designated by the Government of the United Arab Emirates and the term "enterprise of France" means an enterprise designated by the French Government. 
b) The lists of enterprises designated by each Government shall be exchanged by letter through the diplomatic channel and shall be modified following the same procedure. 

5. If the place of effective management of a shipping enterprise is aboard a ship, then it shall be deemed to be situated in the State in which the home harbour of the ship is situated, or, if there is no such home harbour, in the State of which the operator of the ship is a resident. 

6. The provisions of the preceding paragraphs shall also apply to profits from the participation in a pool, a joint business or an international operating agency. 

1. Dividends paid by a company of one State to a resident of the other State may be taxed in the first-mentioned State only if: 

- the recipient of the dividends holds, directly or indirectly, more than 25 per cent of the capital of the company paying the dividends, but the tax so charged shall not exceed 5 per cent of the gross amount of the dividends, or 
- the holding in respect of which the dividends are paid is effectively connected either with a business carried on in that State by the recipient of the dividends through a permanent establishment situated therein or with independent personal services performed in that State by the recipient of the dividends from a fixed base situated therein. 

3. The term "dividends" as used in this Article means income from shares, "jouissance" shares or "jouissance" rights, mining shares, founders' shares or other rights, not being debt-claims, as well as income subjected to the system of distribution by the tax laws of the State of which the company making the distribution is a resident. 

4. A resident of the United Arab Emirates who receives dividends paid by a company which is a resident of France may obtain a refund of any prepayment (precompte) paid by that company in respect of such dividends. The gross amount of the prepayment (precompte) refunded shall be deemed to be a dividend for the purposes of the application of the provisions of this Convention as a whole. 

1. Income from debt-claims arising in one State and paid to a resident of the other State may be taxed in the first-mentioned State, but if the debt-claim in respect of which the income is paid is not effectively connected either with a business carried on in that State by the recipient of the income through a permanent establishment situated therein, or with independent personal services performed in that State by the recipient of the income from a fixed base situated therein: 

a) No tax shall be levied in that State if such income is paid: i. in connection with any business transaction, or ii. in respect of loans of any kind advanced by a bank or by a State itself, or iii. in respect of negotiable bonds. 
b) The tax may not exceed 5 per cent of the gross amount of the income in other cases. 

3. The term "income from debt-claims" as used in this Article means the income from debt-claims of every kind, whether or not secured by mortgage and whether or not carrying a right to participate in the debtor's profits, and, in particular, income from government securities and income from bonds or debentures, including premiums and prizes attaching to such securities, bonds or debentures. 

1. Royalties arising in one State and paid to a resident of the other State may be taxed in the first-mentioned State only if the right or property in respect of which the royalties are paid is effectively connected either with a business carried on in that State by the recipient of the royalties through a permanent establishment situated therein, or with independent personal services performed in that State by the recipient of the royalties from a fixed base situated therein. 

2. The term "royalties" as used in this article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work, including cinematograph films, or films or tapes used for radio or television broadcasting, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience. 

1.
a) Gains derived by a resident of one State from the alienation of immovable property referred to in article 5 and situated in the other State may be taxed in that other State. 
b) Gains from the alienation of shares in a company more than 80 per cent of the assets of which consists of immovable property or of rights relating to such property may be taxed in the State in which the immovable property is situated, where, under the laws of that State, such gains are subjected to the same tax regime as gains from the alienation of immovable property. As regards the application of this provision, immovable property used by that company in its own business or agricultural operations or in the performance of independent personal services shall not be taken into consideration. 

2. Gains from the alienation of any property other than that referred to in paragraph 1 may be taxed only in the State of which the alienator is a resident, unless the property in respect of which the gain is realized is effectively connected either with a business activity carried on in the other State by the alienator through a permanent establishment situated therein, or with independent personal services performed in the other State by the alienator from a fixed base situated therein. 

3. Notwithstanding the provisions of paragraph 2, gains from the alienation of shares representing a substantial participation in the capital of a company may be taxed in the State of which the company is a resident. There is deemed to be a substantial participation when the alienator holds, directly or indirectly, shares which, together, entitle him to more than 25 per cent of the profits of the company. 

1. Income derived by a resident of one State in respect of professional services or other activities of an independent character shall be taxable only in that State, unless he has a fixed base regularly available to him in the other State for the purpose of performing his activities. If he has such a fixed base available to him, the income may be taxed in the other State but only so much of it as is attributable to that fixed base. 

2. The term "professional services" includes especially independent scientific, literary, artistic, educational or teaching activities, as well as the independent activities of physicians, lawyers, engineers, architects, dentists and accountants. 

1. Subject to the provisions of Articles 14, 15 and 16, salaries, wages and other similar remuneration derived by a resident of one State in respect of an employment shall be taxable only in that State, unless the employment is exercised in the other State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State. 

2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of one State in respect of an employment exercised in the other State shall be taxable only in the first-mentioned State if: 

a) The recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the fiscal year concerned; and 
b) The remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and 
c) The remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State. 

4. Notwithstanding the preceding provisions of this article, remuneration derived by a resident of one State in respect of an employment exercised aboard a ship or aircraft operated in international traffic may be taxed only in that State. 

1. Subject to the provisions of Article 15, pensions and other similar remuneration paid to a resident of one State in consideration of past employment shall be taxable only in that State. 

2. Notwithstanding the provisions of paragraph 1, pensions paid and other payments made under the social security legislation of one State may be taxed in that State. 

1. Remuneration other than a pension paid by one State or a local authority thereof or one of their bodies corporate governed by public law to an individual in respect of services rendered to that State or authority or body corporate governed by public law shall be taxable only in that State. 

2. Any pension paid by, or out of funds created by, one State or a local authority thereof or one of their bodies corporate governed by public law to an individual in respect of services rendered to that State or authority or body corporate governed by public law shall be taxable only in that State. 

3. The provisions of Articles 13 and 14 shall apply to remuneration and pensions in respect of services rendered in connection with a business carried on by one State or a local authority thereof or one of their bodies corporate governed by public law. 

1. Payments which a student or business apprentice who is or was immediately before visiting one State a resident of the other State and who is present in the first-mentioned State solely for the purpose of his education or training receives for the purpose of his maintenance, education or training shall not be taxed in that State, provided that such payments arise from sources outside that State. 

2. Remuneration which a student or business apprentice who is or was immediately before visiting one State a resident of the other State and who is present in the first-mentioned State solely for the purpose of his education or training receives in respect of services rendered in the first-mentioned State shall not be taxed in the first-mentioned State, provided that such services are related to his education or training or that such services are necessary to supplement the resources available to him for his maintenance. 

1. Immovable property shall be subjected to the inheritance tax only in the State in which such property is situated. 

2. Tangible and intangible movable property which is effectively connected with the performance of independent personal services or the carrying on of business in that State through a permanent establishment or from a fixed base situated therein shall be subjected to the inheritance tax only in that State. 

3. Tangible and intangible movable property (including securities and deposits) to which paragraph 2 of this Article is not applicable shall be subjected to the inheritance tax only in the State of which the deceased was a resident at the time of his death. 

1. Nothing in this Convention shall prevent the application of any more favourable tax regime which might be provided for by the French domestic law in force in respect of foreign public investment. 

2. Individuals who are residents of the United Arab Emirates and who have at their disposal one or more dwellings for their private use in France, without having their fiscal domicile therein for the purposes of French legislation, shall be exempt from tax on the income established on the basis of the rental value of the dwelling or dwellings. 

3. Interest, royalties and other costs paid by an enterprise of one State to a resident of the other State shall be deductible in the determination of the taxable profits of that enterprise on the same conditions as if they had been paid to a resident of the first-mentioned State. 

4. If a person who is a resident of one State for the purposes of the domestic legislation of that State is deemed to be a resident of the other State on the basis of the criterion of nationality referred to in Article 4, paragraph 2 (c), the first-mentioned State may refuse to grant that person the tax exemptions or reductions provided for in the Convention in respect of residents of the other State, but shall nevertheless treat that person as a non-resident for the purposes of the application of its domestic law. 

A. Profits and other real income derived from the United Arab Emirates and taxable in that country in accordance with the provisions of this Convention shall also be taxable in France where they are payable to a resident of France. The tax paid in the United Arab Emirates shall not be deductible for the purposes of calculating the income taxable in France, but the recipient shall be entitled to a tax credit to be deducted from the French tax covering such income. This tax credit shall be equal to: 

- in the case of the income referred to in Articles 8 and 9, the amount of the tax paid in the United Arab Emirates, in accordance with those articles. It may not, however, exceed the amount of the French tax corresponding to such income; 
-in the case of all other income, the amount of the corresponding French tax. This provision shall also be applicable to the remuneration referred to in Article 15 where the recipient is a resident of France. 

C. Property which represents the estate of a resident of France shall be exempt from the French taxes referred to in Article 2, paragraph 1(a), where such property is taxable in the United Arab Emirates under this Convention. France shall, however, retain the right to calculate the tax on the property to be levied in France under this Convention according to the average rate applicable to the property as a whole permissible under its domestic law. 

Double taxation shall be avoided in accordance with the provisions of the legislation of the State of the United Arab Emirates. 

1. Where a person considers that the actions of one or both of the States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the State of which he is a resident. The case must be presented within two years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention. 

2. The competent authority shall endeavor, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other State, with a view to the avoidance of taxation which is not in accordance with this Convention. Any agreement reached shall be implemented notwithstanding any time-limits in the domestic law of the two States. 

3. The competent authorities of the two States shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the Convention. They may also consult together for the elimination of double taxation in cases not provided for in the Convention. 

4. The competent authorities of the two States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs. If it would appear that oral exchanges of views would facilitate an agreement, such exchanges of views may take place through a commission Composed of representatives of the competent authorities of those States. 

5. The competent authorities of the two States shall decide by mutual agreement the modalities for the application of the Convention, in particular the formalities to be completed by residents of one State in order to obtain in the other State the tax reductions or exemptions provided for by the Convention. 

Nothing in this Convention shall affect the fiscal privileges of members of diplomatic missions and their personal domestics, of members of consular missions, or of members of permanent missions to international organizations under the general rules of international law or under the provisions of special agreements. 

1. This Convention shall apply: 

a) In the case of the United Arab Emirates, to the territory of the United Arab Emirates and to the islands pertaining thereto, including the territorial sea and any area beyond the territorial sea within which, in accordance with international law, the State of the United Arab Emirates has sovereign rights for the purposes of the exploration and exploitation of the resources of the sea bed and the subsoil thereof, and the adjacent waters. 
b) In the case of France, to the European and overseas departments of the French Republic, including the territorial sea and any area beyond the territorial sea within which, in accordance with international law, the French Republic has sovereign rights for the purposes of the exploration and exploitation of the resources of the seabed and the subsoil thereof, and the adjacent waters. 

3. Unless otherwise agreed by the two States, the termination of the Convention by one of them under Article 24 shall also terminate, in the manner provided for in that article, the application of the Convention to any territory to which it has been extended under this article. 

1. Each State shall notify to the other the completion of the procedures required by its law for the entry into force of this Convention. It shall enter into force on the first day of the second month following the receipt of the later of these notifications. 

2. Its provisions shall apply for the first time: 

a) As regards taxes withheld at source, to amounts payable on or after the date of entry into force of this Convention; 
b) As regards other taxes on income, to income derived during the calendar year in which this Convention enters into force, or relating to the accounting period ending during that year; 
c) As regards the inheritance tax, to the estates of persons deceased on or after the date of entry into force of this Convention; 
d) As regards the business tax referred to in article 7, to the tax imposed in respect of the year in which this Convention enters into force. 

The following provisions of the Convention shall cease to have effect as specified below: 

a) As regards taxes withheld at source, to amounts payable on or before 31 December of the calendar year at the end of which it shall cease to have effect; 
b) As regards other taxes on income, to income derived during the calendar year at the end of which it shall cease to have effect, or relating to the accounting period ending during that year;
c) As regards the inheritance tax, to the estates of persons deceased on or before 31 December of the calendar year at the end of which it shall cease to have effect; 
d) As regards the business tax, to the tax levied in respect of the year for the end of which the termination has been notified.