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Poland and UAE Exchange of Notes to Provide the Abu Dhabi Pension Fund is a Qualifying Government Institution for Tax Treaty Purposes

15 April 2024

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Treaty Development

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Poland-United Arab Emirates

Poland's Ministry of Finance has published the exchange of notes signed with the United Arab Emirates (UAE) in 2023 to provide that the Abu Dhabi Pension Fund (ADPF) is a qualifying government institution and a resident of the UAE for the purpose of the 1993 tax treaty between the two countries. As such, the ADPF is eligible for a withholding tax exemption under Articles 10 (Dividends) and 11 (Interest).