34. pants

DARBĪBAS IZBEIGŠANA

Šī Konvencija ir spēkā uz nenoteiktu laiku, kamēr viena

Līgumslēdzēja Valsts tās darbību izbeidz. Katra Līgumslēdzēja

Valsts var izbeigt šīs Konvencijas darbību, iesniedzot pa

diplomātiskajiem kanāliem rakstisku paziņojumu par izbeigšanu

vismaz sešus mēnešus pirms jebkura kalendārā gada beigām, kas

seko piecu gadu periodam sākot ar Konvencijas noteikumu

piemērošanas uzsākšanas gadu. Šajā gadījumā Konvencijas darbība

abās Līgumslēdzējās Valstīs tiek izbeigta:

a) attiecībā uz nodokļiem, ko ietur ienākuma izmaksas brīdī -

ienākumam, kas gūts janvāra pirmajā dienā vai pēc tās kalendārajā

gadā, kas seko gadam, kurā ir iesniegts paziņojums par darbības

izbeigšanu;

b) attiecībā uz pārējiem ienākuma nodokļiem un kapitāla

nodokļiem - nodokļiem, kas maksājami jebkurā taksācijas gadā, kas

sākas janvāra pirmajā dienā vai pēc tās kalendārajā gadā, kas

seko gadam, kurā ir iesniegts paziņojums par darbības

izbeigšanu.

To apliecinot, būdami pienācīgi pilnvaroti, šo Konvenciju ir

parakstījuši.

Konvencija sastādīta Abudabi divos eksemplāros 2012.gada

11.martā latviešu, arābu un angļu valodā, turklāt visi trīs

teksti ir vienlīdz autentiski. Atšķirīgas interpretācijas

gadījumā noteicošais ir teksts angļu valodā.

Latvijas

Republikas valdības vārdā

Apvienoto Arābu

Emirātu valdības vārdā

Māris Selga

Ebeid Hamid El-Tayer

Latvijas

Republikas Ārkārtējais un pilnvarotais vēstnieks Apvienotajos

Arābu Emirātos

Valsts ministrs finanšu lietās

PROTOKOLS

Parakstot Latvijas Republikas valdības un Apvienoto Arābu

Emirātu valdības Konvenciju par nodokļu dubultās uzlikšanas un

nodokļu nemaksāšanas novēršanu attiecībā uz ienākuma un kapitāla

nodokļiem (turpmāk - Konvencija), puses ir vienojušās par tālāk

minētajiem noteikumiem, kas ir Konvencijas neatņemama

sastāvdaļa.

1. Attiecībā uz 2.panta pirmo daļu:

Tiek saprasts, ka Apvienotie Arābu Emirāti sastāv no:

− federālās valsts, kas sastāv no septiņiem Emirātiem,

− federālās valsts vietējām valdībām (Abu Dabi emirāta,

Dubajas emirāta, Šardžas emirāta, Adžmanas emirāta, Umm Al

Kaivainas emirāta, Raselhaimas emirāta un Fudžeiras emirāta),

un

− vietējo valdību vietējām pašvaldībām.

2. Attiecībā uz 4.panta otrās daļas c) punktu:

Tiek saprasts, ka Apvienoto Arābu Emirātu gadījumā 4.panta

otrās daļas c) apakšpunktā definētās valdības institūcijas ietver

Abu Dabi investīciju pārvaldi, Abu Dabi investīciju padomi,

Mubadala attīstības sabiedrību (Mubadala), Dubajas pasauli,

Dubajas investīciju sabiedrību (DIC), AAE investīciju pārvaldi un

Starptautisko naftas investīciju sabiedrību (IPIC).

3. Attiecībā uz 7.panta trešo daļu:

Tiek saprasts, ka izdevumu atskaitīšanas nosacījumi tiek

noteikti saskaņā ar tās Līgumslēdzējas Valsts, kurā atrodas

pastāvīgā pārstāvniecība, nacionālajiem normatīvajiem aktiem,

ņemot vērā 28.panta noteikumus, it īpaši trešo un ceturto

daļu.

4. Attiecībā uz 8.panta pirmo daļu:

Tiek saprasts, ka termins "peļņa" nozīmē:

− peļņu, neto peļņu, bruto ieņēmumus un ieņēmumus, ko tieši

gūst no kuģu vai gaisa kuģu izmantošanas starptautiskajā

satiksmē;

− procentus no summām, kas tieši radušās no kuģu vai gaisa

kuģu izmantošanas starptautiskajā satiksmē, kas tiek gūti

papildus šādai izmantošanai;

− ienākumu no biļešu tirdzniecības tāda uzņēmuma labā, kas

izmanto kuģus vai gaisa kuģus starptautiskajā satiksmē;

− ienākumu no inženiertehnisko pakalpojumu sniegšanas un

jebkuru citu ienākumu, kas rodas no citiem tehniskajiem

pakalpojumiem, ja šādu pakalpojumu sniegšana notiek papildus

gaisa kuģu izmantošanai starptautiskajā satiksmē.

5. Attiecībā uz 11.panta trešo daļu:

Ja Līgumslēdzējas Valsts valdība netieši, izmantojot aģentu

vai kā savādāk, piedalās aizdevuma piešķiršanā, tad trešajā daļā

noteiktais atbrīvojums tiek piemērots proporcionāli šīs valdības

līdzdalībai šādā aizdevumā. Līdzdalība tiek apliecināta ar šīs

Līgumslēdzējas Valsts kompetentās iestādes izsniegtu

sertifikātu.

6. Attiecībā uz 13.pantu:

Tiek saprasts, ka piektā daļa ietver kapitāla pieaugumu, ko

Līgumslēdzējas Valsts rezidents, ieskaitot šīs valsts valdības

institūcijas vai investīciju sabiedrības, gūst no akciju un

pamatkapitāla daļu, vai citas tām pielīdzināmas līdzdalības,

izņemot otrajā daļā minētās, atsavināšanas, un šādam pieaugumam

nodokļi tiek uzlikti tikai tajā valstī, kuras rezidents ir

atsavinātājs.

7. Attiecībā uz 30.pantu:

Ja saskaņā ar šo pantu Līgumslēdzēja Valsts pieprasa sniegt

informāciju, otrai Līgumslēdzējai Valstij ir jāiegūst pieprasītā

informācija, ieskaitot banku, citu finanšu institūciju, pārstāvju

vai personu, kuras darbojas kā pilnvarnieki vai uzticības

personas, rīcībā esošo informāciju, tādā pat veidā un tikpat

lielā mērā, it kā pirmās minētās valsts nodoklis būtu šīs otras

valsts nodoklis un to iekasētu šī otra valsts, pat ja šai otrai

valstij šāda informācija nav nepieciešama savām nodokļu

uzlikšanas vajadzībām.

To apliecinot, būdami pienācīgi pilnvaroti, šo Protokolu ir

parakstījuši.

Protokols sastādīts Abudabi divos eksemplāros 2012.gada

11.martā latviešu, arābu un angļu valodā, turklāt visi trīs

teksti ir vienlīdz autentiski. Atšķirīgas interpretācijas

gadījumā noteicošais ir teksts angļu valodā.

Latvijas

Republikas valdības vārdā

Apvienoto Arābu

Emirātu valdības vārdā

Māris Selga

Ebeid Hamid El-Tayer

Latvijas Republikas

Ārkārtējais un pilnvarotais vēstnieks Apvienotajos Arābu

Emirātos

Valsts ministrs finanšu

lietās

CONVENTION

BETWEEN

THE GOVERNMENT OF THE REPUBLIC OF LATVIA

AND

THE GOVERNMENT OF THE UNITED ARAB EMIRATES

FOR THE AVOIDANCE OF DOUBLE TAXATION

AND THE PREVENTION OF FISCAL EVASION

WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL

The Government of the Republic of Latvia and the Government of

the United Arab Emirates,

Desiring to promote and strengthen their economic relations by

concluding a Convention for the avoidance of double taxation and

the prevention of fiscal evasion with respect to taxes on income

and on capital,

Have agreed as follows:

Article 1

PERSONS COVERED

This Convention shall apply to persons who are residents of

one or both of the Contracting States.

Article 2

TAXES COVERED

1. This Convention shall apply to taxes on income and on

capital imposed on behalf of a Contracting State or of its local

governments or local authorities, irrespective of the manner in

which they are levied.

2. There shall be regarded as taxes on income and on capital

all taxes imposed on total income, on total capital, or on

elements of income or of capital, including taxes on gains from

the alienation of movable or immovable property, as well as taxes

on capital appreciation.

3. The existing taxes to which the Convention shall apply are

in particular:

a) in Latvia:

(i) the enterprise income tax (uznemumu ienakuma

nodoklis);

(ii) the personal income tax (iedzivotaju ienakuma

nodoklis);

(iii) the immovable property tax (nekustama ipasuma

nodoklis);

(hereinafter referred to as "Latvian tax");

b) in the United Arab Emirates:

(i) income tax; and

(ii) corporation tax;

(hereinafter referred to as "United Arab Emirates

tax").

4. The Convention shall apply also to any identical or

substantially similar taxes which are imposed after the date of

signature of the Convention in addition to, or in place of, the

existing taxes. The competent authorities of the Contracting

States shall notify each other of any significant changes which

have been made in their respective taxation laws.

Article 3

GENERAL DEFINITIONS

1. For the purposes of this Convention, unless the context

otherwise requires:

a) the term "Latvia" means the Republic of Latvia

and, when used in the geographical sense, means the territory of

the Republic of Latvia and any other area adjacent to the

territorial waters of the Republic of Latvia within which under

the laws of Latvia and in accordance with international law, the

rights of Latvia may be exercised with respect to the sea bed and

its sub-soil and their natural resources;

b) the term "United Arab Emirates" means the United

Arab Emirates and, when used in a geographical sense, means the

area in which the territory is under its sovereignty as well as

the territorial sea, airspace and submarine areas over which the

United Arab Emirates exercises, in conformity with international

law and the law of United Arab Emirates sovereign rights,

including the mainland and islands under its jurisdiction in

respect of any activity carried on in connection with the

exploration for or the exploitation of the natural resources;

c) the terms "a Contracting State" and "the

other Contracting State" mean Latvia or the United Arab

Emirates, as the context requires;

d) the term "tax" means Latvian tax or the United

Arab Emirates tax, as the context requires;

e) the term "person" includes an individual, a

company and any other body of persons;

f) the term "company" means any body corporate or

any entity which is treated as a body corporate for tax

purposes;

g) the terms "enterprise of a Contracting State" and

"enterprise of the other Contracting State" mean

respectively an enterprise carried on by a resident of a

Contracting State and an enterprise carried on by a resident of

the other Contracting State;

h) the term "international traffic" means any

transport by a ship or aircraft operated by an enterprise of a

Contracting State, except when the ship or aircraft is operated

solely between places in the other Contracting State;

i) the term "competent authority" means:

(i) in Latvia, the Ministry of Finance or its authorised

representative;

(ii) in the United Arab Emirates, the Ministry of Finance or

its authorised representative;

j) the term "national" means:

(i) any individual possessing the nationality of a Contracting

State; and

(ii) any legal person, partnership or association deriving its

status as such from the laws in force in a Contracting State.

2. As regards the application of the Convention at any time by

a Contracting States, any term not defined therein shall, unless

the context otherwise requires, have the meaning that it has at

that time under the law of that State for the purposes of the

taxes to which the Convention applies, any meaning under the

applicable tax laws of that State prevailing over a meaning given

to the term under other laws of that State.

Article 4

RESIDENT

1. For the purposes of this Convention, the term

"resident of a Contracting State" means:

a) in Latvia, any person who, under the laws of Latvia, is

liable to tax therein by reason of his domicile, residence, place

of management, place of incorporation or any other criterion of a

similar nature, but does not include any person who is liable to

tax in that State in respect only of income from sources in that

State or capital situated therein;

b) in the United Arab Emirates:

(i) an individual who is a national of the United Arab

Emirates, provided that the individual has a substantial

presence, permanent home or habitual abode in the United Arab

Emirates and that individual's personal and economic

relations are closer to the United Arab Emirates than to any

other State;

(ii) a company which is established under the law of the

United Arab Emirates.

2. For the purposes of paragraph 1, the term "resident of

a Contracting State" also includes:

a) that State, any local government, local authority

thereof;

b) a pension fund that is recognised and controlled according

to the statutory provisions of a Contracting State and the income

of which is generally exempt from tax in that State;

c) a governmental institution of a Contracting State. Any

institution shall be deemed to be a governmental institution

which has been created, wholly owned and controlled by the

Government of one of the Contracting States or of its local

governments and which is recognized as such by mutual agreement

of the competent authorities of the Contracting States.

3. Where by reason of the provisions of paragraph 1 an

individual is a resident of both Contracting States, then his

status shall be determined as follows:

a) he shall be deemed to be a resident only 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 only 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 only

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 only 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 Contracting States shall settle

the question by mutual agreement.

4. Where by reason of the provisions of paragraph 1 a person

other than an individual is a resident of both Contracting

States, the competent authorities of the Contracting States shall

endeavour to settle the question by mutual agreement.

Article 5

PERMANENT ESTABLISHMENT

1. 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.

2. The term "permanent establishment" includes

especially:

a) a place of management;

b) a branch;

c) an office;

d) a factory;

e) a workshop;

f) a mine, an oil or gas well, a quarry or any other place of

extraction of natural resources, and

g) a farm or plantation.

3. A building site, a construction, assembly or installation

project or a supervisory activity connected therewith constitutes

a permanent establishment only if such site, project or activity

lasts for a period of more than nine months.

4. 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 activities mentioned in sub-paragraphs 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.

5. Notwithstanding the provisions of paragraphs 1 and 2, where

a person - other than an agent of an independent status to whom

paragraph 6 applies - is acting on behalf of an enterprise and

has, and habitually exercises, in a Contracting State an

authority to conclude contracts in the name of the enterprise,

that enterprise shall be deemed to have a permanent establishment

in that State in respect of any activities which that person

undertakes for the enterprise, unless the activities of such

person are limited to those mentioned in paragraph 4 which, if

exercised through a fixed place of business, would not make this

fixed place of business a permanent establishment under the

provisions of that paragraph.

6. An enterprise shall not be deemed to have a permanent

establishment in a Contracting 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.

7. The fact that a company which is a resident of a

Contracting State controls or is controlled by a company which is

a resident of the other Contracting 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.

Article 6

INCOME FROM IMMOVABLE PROPERTY

1. Income derived by a resident of a Contracting State from

immovable property (including income from agriculture or

forestry) situated in the other Contracting 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 Contracting 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,

any option or similar right to acquire immovable property,

usufruct of immovable property 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 apply to income derived

from the direct use, letting, or use in any other form of

immovable property, as well as income from the alienation of

immovable property.

4. The provisions of paragraphs 1 and 3 shall also apply to

the income from immovable property of an enterprise and to income

from immovable property used for the performance of independent

personal services.

Article 7

BUSINESS PROFITS

1. The profits of an enterprise of a Contracting State shall

be taxable only in that State unless the enterprise carries on

business in the other Contracting 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. Subject to the provisions of paragraph 3, where an

enterprise of a Contracting State carries on business in the

other Contracting State through a permanent establishment

situated therein, there shall in each Contracting State be

attributed to that permanent establishment the profits which it

might be expected to make if it were a distinct and separate

enterprise engaged in the same or similar activities under the

same or similar conditions and dealing wholly independently with

the enterprise of which it is a permanent establishment.

3. In determining the profits of a permanent establishment in

a Contracting State, there shall be allowed as deductions

expenses which are incurred for the purposes of the permanent

establishment, including executive and general administrative

expenses so incurred, whether in the State in which the permanent

establishment is situated or elsewhere.

4. Insofar as it has been customary in a Contracting State to

determine the profits to be attributed to a permanent

establishment on the basis of an apportionment of the total

profits of the enterprise to its various parts, nothing in

paragraph 2 shall preclude that Contracting State from

determining the profits to be taxed by such an apportionment as

may be customary; the method of apportionment adopted shall,

however, be such that the result shall be in accordance with the

principles contained in this Article.

5. No profits shall be attributed to a permanent establishment

by reason of the mere purchase by that permanent establishment of

goods or merchandise for the enterprise.

6. For the purposes of the preceding paragraphs, the profits

to be attributed to the permanent establishment shall be

determined by the same method year by year unless there is good

and sufficient reason to the contrary.

7. Where profits include items of income which are dealt with

separately in other Articles of this Convention, then the

provisions of those Articles shall not be affected by the

provisions of this Article.

Article 8

SHIPPING AND AIR TRANSPORT

1. Profits of an enterprise of a Contracting State from the

operation of ships or aircraft in international traffic shall be

taxable only in that State.

2. For the purposes of this Article, profits of an enterprise

from the operation of ships or aircraft in international traffic

include:

a) profits from the rental on a bareboat basis of ships or

aircraft; and

b) profits from the use, maintenance or rental of containers

(including trailers and related equipment for the transport of

containers) used for the transport of goods or merchandise;

where such rental or such use, maintenance or rental, as the

case may be, is incidental to the operation of ships or aircraft

by the enterprise in international traffic.

3. The provisions of paragraph 1 shall also apply to profits

from the participation in a pool, a joint business or an

international operating agency.

Article 9

ASSOCIATED ENTERPRISES

1. Where

a) an enterprise of a Contracting State participates directly

or indirectly in the management, control or capital of an

enterprise of the other Contracting State, or

b) the same persons participate directly or indirectly in the

management, control or capital of an enterprise of a Contracting

State and an enterprise of the other Contracting State,

and in either case conditions are made or imposed between the

two enterprises in their commercial or financial relations which

differ from those which would be made between independent

enterprises, then any profits which would, but for those

conditions, have accrued to one of the enterprises, but, by

reason of those conditions, have not so accrued, may be included

in the profits of that enterprise and taxed accordingly.

2. Where a Contracting State includes in the profits of an

enterprise of that State - and taxes accordingly - profits on

which an enterprise of the other Contracting State has been

charged to tax in that other State and the profits so included

are profits which would have accrued to the enterprise of the

first-mentioned State if the conditions made between the two

enterprises had been those which would have been made between

independent enterprises, then that other State shall make an

appropriate adjustment to the amount of the tax charged therein

on those profits. In determining such adjustment, due regard

shall be had to the other provisions of this Convention and the

competent authorities of the Contracting States shall if

necessary consult each other.

Article 10

DIVIDENDS

1. Dividends paid by a company which is a resident of a

Contracting State to a resident of the other Contracting State

may be taxed in that other State.

2. However, such dividends may also be taxed in the

Contracting State of which the company paying the dividends is a

resident and according to the laws of that State, but if the

beneficial owner of the dividends is a resident of the other

Contracting State, the tax so charged shall not exceed 5 per cent

of the gross amount of the dividends.

This paragraph shall not affect the taxation of the company in

respect of the profits out of which the dividends are paid.

3. Notwithstanding the provisions of paragraphs 1 and 2 of

this Article, dividends paid by a company which is a resident of

a Contracting State shall be taxable only in the other

Contracting State if the beneficial owner of the dividends is

that other State itself, a local government, local authority, or

the Central Bank thereof, or any governmental institution of the

other State as defined in subparagraph c) of paragraph 2 of

Article 4.

4. The term "dividends" as used in this Article

means income from shares or other rights, not being debt-claims,

participating in profits, as well as income from other rights

which is subjected to the same taxation treatment as income from

shares by the laws of the State of which the company making the

distribution is a resident.

5. The provisions of paragraphs 1 and 2 shall not apply if the

beneficial owner of the dividends, being a resident of a

Contracting State, carries on business in the other Contracting

State of which the company paying the dividends is a resident,

through a permanent establishment situated therein, or performs

in that other State independent personal services from a fixed

base situated therein and the holding in respect of which the

dividends are paid is effectively connected with such permanent

establishment or fixed base. In such case the provisions of

Article 7 or Article 14, as the case may be, shall apply.

6. Where a company which is a resident of a Contracting State

derives profits or income from the other Contracting State, that

other State may not impose any tax on the dividends paid by the

company, except insofar as such dividends are paid to a resident

of that other State or insofar as the holding in respect of which

the dividends are paid is effectively connected with a permanent

establishment or a fixed base situated in that other State, nor

subject the company's undistributed profits to a tax on the

company's undistributed profits, even if the dividends paid

or the undistributed profits consist wholly or partly of profits

or income arising in such other State.

Article 11

INTEREST

1. Interest arising in a Contracting State and paid to a

resident of the other Contracting State may be taxed in that

other State.

2. However, such interest may also be taxed in the Contracting

State in which it arises and according to the laws of that State,

but if the beneficial owner of the interest is a resident of the

other Contracting State, the tax so charged shall not exceed 2,5

per cent of the gross amount of the interest.

3. Notwithstanding the provisions of paragraphs 1 and 2 of

this Article, interest arising in a Contracting State shall be

taxable only in the other Contracting State if the beneficial

owner of the interest is that other State itself, a local

government, a local authority, or the Central Bank thereof, or

any governmental institution of the other Contracting State as

defined in subparagraph c) of paragraph 2 of Article 4, or

interest arising in a Contracting State on any loan of whatever

kind granted by a bank which is a resident of that other State,

shall be exempt from tax in the first-mentioned State.

4. The term "interest" as used in this Article means

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. The term "interest" shall not include any

income which is treated as a dividend under the provisions of

Article 10. Penalty charges for late payment shall not be

regarded as interest for the purpose of this Article.

5. The provisions of paragraphs 1, 2 and 3 shall not apply if

the beneficial owner of the interest, being a resident of a

Contracting State, carries on business in the other Contracting

State in which the interest arises, through a permanent

establishment situated therein, or performs in that other State

independent personal services from a fixed base situated therein,

and the debt-claim in respect of which the interest is paid is

effectively connected with such permanent establishment or fixed

base. In such case the provisions of Article 7 or Article 14, as

the case may be, shall apply.

6. Interest shall be deemed to arise in a Contracting State

when the payer is a resident of that State. Where, however, the

person paying the interest, whether he is a resident of a

Contracting State or not, has in a Contracting State a permanent

establishment or a fixed base in connection with which the

indebtedness on which the interest is paid was incurred, and such

interest is borne by such permanent establishment or fixed base,

then such interest shall be deemed to arise in the State in which

the permanent establishment or fixed base is situated.

7. Where, by reason of a special relationship between the

payer and the beneficial owner or between both of them and some

other person, the amount of the interest, having regard to the

debt-claim for which it is paid, exceeds the amount which would

have been agreed upon by the payer and the beneficial owner in

the absence of such relationship, the provisions of this Article

shall apply only to the last-mentioned amount. In such case, the

excess part of the payments shall remain taxable according to the

laws of each Contracting State, due regard being had to the other

provisions of this Convention.

Article 12

ROYALTIES

1. Royalties arising in a Contracting State and paid to a

resident of the other Contracting State may be taxed in that

other State.

2. However, such royalties may also be taxed in the

Contracting State in which they arise and according to the laws

of that State, but if the beneficial owner of the royalties is a

resident of the other Contracting State, the tax so charged shall

not exceed 5 per cent of the gross amount of the royalties.

3. 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 and films or

tapes and other means of image or sound reproduction for radio or

television broad-casting, any patent, trade mark, design or

model, plan, secret formula or process, or for the use of, or the

right to use, industrial, commercial or scientific equipment, or

for information concerning industrial, commercial or scientific

experience.

4. The provisions of paragraphs 1 and 2 shall not apply if the

beneficial owner of the royalties, being a resident of a

Contracting State, carries on business in the other Contracting

State in which the royalties arise, through a permanent

establishment situated therein or performs in that other State

independent personal services from a fixed base situated therein

and the right or property in respect of which the royalties are

paid is effectively connected with such permanent establishment

or fixed base. In such case the provisions of Article 7 or

Article 14, as the case may be, shall apply.

5. Royalties shall be deemed to arise in a Contracting State

when the payer is a resident of that State. Where, however, the

person paying the royalties, whether he is a resident of a

Contracting State or not, has in a Contracting State a permanent

establishment or a fixed base in connection with which the

liability to pay the royalties was incurred, and such royalties

are borne by such permanent establishment or fixed base, then

such royalties shall be deemed to arise in the State in which the

permanent establishment or fixed base is situated.

6. Where, by reason of a special relationship between the

payer and the beneficial owner or between both of them and some

other person, the amount of the royalties, having regard to the

use, right or information for which they are paid, exceeds the

amount which would have been agreed upon by the payer and the

beneficial owner in the absence of such relationship, the

provisions of this Article shall apply only to the last-mentioned

amount. In such case, the excess part of the payments shall

remain taxable according to the laws of each Contracting State,

due regard being had to the other provisions of this

Convention.

Article 13

CAPITAL GAINS

1. Gains derived by a resident of a Contracting State from the

alienation of immovable property referred to in Article 6 and

situated in the other Contracting State may be taxed in that

other State.

2. Gains derived by a resident of a Contracting State from the

alienation of:

a) shares, the value of which is derived directly or

indirectly principally from immovable property situated in that

other State; or

b) an interest in a partnership or other similar entity, the

value of which is derived directly or indirectly principally from

immovable property situated in that other State or from shares

referred to in subparagraph a),

may be taxed in that other State.

3. Gains from the alienation of movable property forming part

of the business property of a permanent establishment which an

enterprise of a Contracting State has in the other Contracting

State or of movable property pertaining to a fixed base available

to a resident of a Contracting State in the other Contracting

State for the purpose of performing independent personal

services, including such gains from the alienation of such a

permanent establishment (alone or with the whole enterprise) or

of such fixed base may be taxed in that other State.

4. Gains derived by an enterprise of a Contracting State

operating ships or aircraft in international traffic from the

alienation of ships or aircraft operated in international traffic

or movable property pertaining to the operation of such ships or

aircraft, shall be taxable only in that State.

5. Gains from the alienation of any property other than that

referred to in paragraphs 1, 2, 3 and 4, shall be taxable only in

the Contracting State of which the alienator is a resident.

Article 14

INDEPENDENT PERSONAL SERVICES

1. Income derived by an individual who is a resident of a

Contracting 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 Contracting State for the purpose of performing his

activities. If he has such a fixed base, the income may be taxed

in the other State but only so much of it as is attributable to

that fixed base. For this purpose, where an individual who is a

resident of a Contracting State stays in the other Contracting

State for a period or periods exceeding in the aggregate 183 days

in any twelve month period commencing or ending in the fiscal

year concerned, he shall be deemed to have a fixed base regularly

available to him in that other State and the income that is

derived from his activities referred to above that are performed

in that other State shall be 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.

Article 15

Dependent personal

services

1. Subject to the provisions of Articles 16, 18, 19 and 21,

salaries, wages and other similar remuneration derived by a

resident of a Contracting State in respect of an employment shall

be taxable only in that State unless the employment is exercised

in the other Contracting 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 a Contracting State in respect of an

employment exercised in the other Contracting 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 any twelve

month period commencing or ending 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.

3. Notwithstanding the preceding provisions of this Article,

remuneration derived in respect of an employment exercised aboard

a ship or aircraft operated in international traffic by an

enterprise of a Contracting State shall be taxable only in that

State unless the remuneration is derived by a resident of the

other Contracting State.

4. Ground staff performing functions of managerial nature and

appointed from head office of an enterprise of a Contracting

State operating aircraft in international traffic to the other

Contracting State shall be exempted from taxes levied on their

remunerations in that other Contracting State.

Article 16

DIRECTORS' FEES

Directors' fees and other similar payments derived by a

resident of a Contracting State in his capacity as a member of

the board of directors or any other similar organ of a company

which is a resident of the other Contracting State may be taxed

in that other State.

Article 17

ARTISTES AND SPORTSMEN

1. Notwithstanding the provisions of Articles 14 and 15,

income derived by a resident of a Contracting State as an

entertainer, such as a theatre, motion picture, radio or

television artiste, or a musician, or as a sportsman, from his

personal activities as such exercised in the other Contracting

State, may be taxed in that other State.

2. Where income in respect of personal activities exercised by

an entertainer or a sportsman in his capacity as such accrues not

to the entertainer or sportsman himself but to another person,

that income may, notwithstanding the provisions of Articles 7, 14

and 15, be taxed in the Contracting State in which the activities

of the entertainer or sportsman are exercised.

3. The provisions of paragraphs 1 and 2 shall not apply to

income derived from activities exercised in a Contracting State

by an entertainer or a sportsman if the visit to that State is

wholly or mainly supported by public funds of one or both of the

Contracting States or local governments or local authorities

thereof. In such case, the income shall be taxable only in the

Contracting State of which the entertainer or sportsman is a

resident.

Article 18

PENSIONS

1. Subject to the provisions of paragraph 2 of Article 19,

pensions and other similar remuneration paid to a resident of a

Contracting State in consideration of past employment shall be

taxable only in that State.

2. Notwithstanding the provisions of paragraph 1 of this

Article and paragraph 2 of Article 19, pensions and other similar

remuneration paid under the social security system of a

Contracting State shall be taxable only in that State.

Article 19

GOVERNMENT SERVICE

1. a) Salaries, wages and other similar remuneration, other

than a pension, paid by a Contracting State or a local government

or a local authority thereof to an individual in respect of

services rendered to that State, government or authority shall be

taxable only in that State.

b) However, such salaries, wages and other similar

remuneration shall be taxable only in the other Contracting State

if the services are rendered in that State and the individual is

a resident of that State who:

(i) is a national of that State; or

(ii) did not become a resident of that State solely for the

purpose of rendering the services.

2. a) Any pension paid by, or out of funds created by, a

Contracting State or a local government or a local authority

thereof to an individual in respect of services rendered to that

State, government or authority shall be taxable only in that

State.

b) However, such pension shall be taxable only in the other

Contracting State if the individual is a resident of, and a

national of, that State.

3. The provisions of Articles 15, 16, 17 and 18 shall apply to

salaries, wages and other similar remuneration, and to pensions,

in respect of services rendered in connection with a business

carried on by a Contracting State or a local government or a

local authority thereof.

Article 20

STUDENTS

Payments which a student, an apprentice or a trainee who is or

was immediately before visiting a Contracting State a resident of

the other Contracting 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.

Article 21

TEACHERS AND RESEARCHERS

1. An individual who visits a Contracting State for the

purpose of teaching or carrying out research at the university,

college or other recognised educational or scientific institution

in that Contracting State and who is or was immediately before

that visit a resident of the other Contracting State, shall be

exempted from taxation in the first-mentioned Contracting State

on remuneration for such teaching or research for a period not

exceeding two years from the date of his first visit for that

purpose.

2. The provisions of this Article shall not apply to income

from research if such research is undertaken not in the public

interest but primarily for the private benefit of a specific

person or persons.

Article 22

OTHER INCOME

1. Items of income of a resident of a Contracting State,

wherever arising, not dealt with in the foregoing Articles of

this Convention shall be taxable only in that State.

2. The provisions of paragraph 1 shall not apply to income,

other than income from immovable property as defined in paragraph

2 of Article 6, if the recipient of such income, being a resident

of a Contracting State, carries on business in the other

Contracting State through a permanent establishment situated

therein, or performs in that other State independent personal

services from a fixed base situated therein, and the right or

property in respect of which the income is paid is effectively

connected with such permanent establishment or fixed base. In

such case the provisions of Article 7 or Article 14, as the case

may be, shall apply.

Article 23

INCOME FROM HYDROCARBONS AND OTHER NATURAL RESOURCES

Nothing in this Convention shall affect the right of a

Contracting State, or any of its local governments or local

authorities thereof, to apply its domestic laws and regulations

related to the taxation of income and profits from hydrocarbons

and other natural resources and associated activities situated in

the territory of that State.

Article 24

PENSION FUNDS

Notwithstanding any provision of this Convention, except

Article 23, income arising in a Contracting State that is derived

by a resident of the other Contracting State mentioned in

subparagraph b) of paragraph 2 of Article 4 that has been

accepted by the competent authority of the first - mentioned

State as a pension fund generally corresponding to a pension fund

recognised as such for tax purposes by that State, shall be

exempt from tax in that State.

Article 25

CAPITAL

1. Capital represented by immovable property referred to in

Article 6, owned by a resident of a Contracting State and

situated in the other Contracting State, may be taxed in that

other State.

2. Capital represented by movable property forming part of the

business property of a permanent establishment which an

enterprise of a Contracting State has in the other Contracting

State or by movable property pertaining to a fixed base available

to a resident of a Contracting State in the other Contracting

State for the purpose of performing independent personal

services, may be taxed in that other State.

3. Capital represented by ships and aircraft operated in

international traffic by an enterprise of a Contracting State and

by movable property pertaining to the operation of such ships and

aircraft, shall be taxable only in that State.

4. All other elements of capital of a resident of a

Contracting State shall be taxable only in that State.

Article 26

LIMITATION OF BENEFITS

1. Notwithstanding any other provision of this Convention, a

company mentioned in subparagraph b) (ii) of paragraph 1 of

Article 4, shall be entitled to the benefits of Articles 7, 8, 10

to 15, 22 and 25, only if such company can prove that:

a) all of the shares of the company are beneficially owned by

residents of the United Arab Emirates; and

b) the principal purpose of establishment of the company or of

the conduct of its business or of the acquisition of a

shareholding or an interest in such company, or of the

acquisition or maintenance by it of the shareholding or other

property, was not to obtain any benefits under this Convention to

the advantage of a person who is not a resident of the United

Arab Emirates.

2. Relief from Latvian taxes under paragraph 1 is conditional

on confirmation by the competent authority of the United Arab

Emirates that the prerequisites mentioned in paragraph 1 have

been fulfilled.

3. The provisions of paragraphs 1 and 2 shall not apply to

companies covered by subparagraph c) of paragraph 2 of Article

4.

Article 27

ELIMINATION OF DOUBLE TAXATION

1. In Latvia, double taxation shall be eliminated as

follows:

a) Where a resident of Latvia derives income or owns capital

which, in accordance with this Convention, may be taxed in the

United Arab Emirates, unless a more favourable treatment is

provided in its domestic law, Latvia shall allow:

(i) as a deduction from the tax on the income of that

resident, an amount equal to the income tax paid thereon in the

United Arab Emirates;

(ii) as a deduction from the tax on the capital of that

resident, an amount equal to the capital tax paid thereon in the

United Arab Emirates.

Such deduction in either case shall not, however, exceed that

part of the income tax or capital tax in Latvia, as computed

before the deduction is given, which is attributable, as the case

may be, to the income or the capital which may be taxed in the

United Arab Emirates.

b) For the purposes of subparagraph a), where a company that

is a resident of Latvia receives a dividend from a company that

is a resident of the United Arab Emirates in which it owns at

least 10 per cent of its shares having full voting rights, the

tax paid in the United Arab Emirates shall include not only the

tax paid on the dividend, but also the appropriate portion of the

tax paid on the underlying profits of the company out of which

the dividend was paid.

2. In the United Arab Emirates, double taxation shall be

eliminated as follows:

a) Where a resident of the United Arab Emirates derives income

or owns capital which in accordance with the provisions of this

Convention may be taxed in Latvia, the United Arab Emirates shall

allow as a deduction from tax on income or on capital of that

person an amount equal to the tax on income or tax on capital

paid in Latvia.

b) Such deductions in either case shall not, however, exceed

that part of income tax or capital tax, as computed before the

deduction is given, which is attributable, as the case may be, to

the income or the capital which may be taxed in Latvia.

Article 28

NON-DISCRIMINATION

1. Nationals of a Contracting State shall not be subjected in

the other Contracting State to any taxation or any requirement

connected therewith, which is other or more burdensome than the

taxation and connected requirements to which nationals of that

other State in the same circumstances, in particular with respect

to residence, are or may be subjected. This provision shall,

notwithstanding the provisions of Article 1, also apply to

persons who are not residents of one or both of the Contracting

States.

2. Stateless persons who are residents of a Contracting State

shall not be subjected in either Contracting State to any

taxation or any requirement connected therewith, which is other

or more burdensome than the taxation and connected requirements

to which nationals of the State concerned in the same

circumstances, in particular with respect to residence, are or

may be subjected.

3. The taxation on a permanent establishment which an

enterprise of a Contracting State has in the other Contracting

State shall not be less favourably levied in that other State

than the taxation levied on enterprises of that other State

carrying on the same activities. This provision shall not be

construed as obliging a Contracting State to grant to residents

of the other Contracting State any personal allowances, reliefs

and reductions for taxation purposes on account of civil status

or family responsibilities which it grants to its own

residents.

4. Except where the provisions of paragraph 1 of Article 9,

paragraph 7 of Article 11, or paragraph 6 of Article 12, apply,

interest, royalties and other disbursements paid by an enterprise

of a Contracting State to a resident of the other Contracting

State shall, for the purpose of determining the taxable profits

of such enterprise, be deductible under the same conditions as if

they had been paid to a resident of the first-mentioned State.

Similarly, any debts of an enterprise of a Contracting State to a

resident of the other Contracting State shall, for the purpose of

determining the taxable capital of such enterprise, be deductible

under the same conditions as if they had been contracted to a

resident of the first-mentioned State.

5. Nothing in this Article shall be construed as imposing a

legal obligation on a Contracting State to extend to the

residents of the other Contracting State the benefit of any

treatment, preference or privilege which may be accorded to any

other State or its residents by virtue of the formation of a

customs union, economic union, a free trade area or by virtue of

any regional or sub-regional arrangement relating wholly or

mainly to taxation, to which the first-mentioned State may be a

party.

6. Enterprises of a Contracting State, the capital of which is

wholly or partly owned or controlled, directly or indirectly, by

one or more residents of the other Contracting State, shall not

be subjected in the first-mentioned State to any taxation or any

requirement connected therewith which is other or more burdensome

than the taxation and connected requirements to which other

similar enterprises of the first-mentioned State are or may be

subjected.

7. The provisions of this Article shall, notwithstanding the

provisions of Article 2, apply to taxes of every kind and

description, except taxes that may be levied in accordance with

Article 23.

Article 29

MUTUAL AGREEMENT PROCEDURE

1. Where a person considers that the actions of one or both of

the Contracting 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

Contracting State of which he is a resident or, if his case comes

under paragraph 1 of Article 28, to that of the Contracting State

of which he is a national. The case must be presented within

three 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 endeavour, 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 Contracting

State, with a view to the avoidance of taxation which is not in

accordance with the Convention. Any agreement reached shall be

implemented notwithstanding any time limits in the domestic law

of the Contracting States.

3. The competent authorities of the Contracting 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 Contracting States may

communicate with each other directly, including through a joint

commission consisting of themselves or their representatives, for

the purpose of reaching an agreement in the sense of the

preceding paragraphs.

Article 30

EXCHANGE OF INFORMATION

1. The competent authorities of the Contracting States shall

exchange such information as is necessary for carrying out the

provisions of this Convention or of the domestic laws of the

Contracting States concerning taxes covered by the Convention

insofar as the taxation thereunder is not contrary to the

Convention. The exchange of information is not restricted by

Article 1. Any information received by a Contracting State shall

be treated as secret in the same manner as information obtained

under the domestic laws of that State and shall be disclosed only

to persons or authorities (including courts and administrative

bodies) concerned with the assessment or collection of, the

enforcement or prosecution in respect of, or the determination of

appeals in relation to, the taxes covered by the Convention. Such

persons or authorities shall use the information only for such

purposes. They may disclose the information in public court

proceedings or in judicial decisions.

2. In no case shall the provisions of paragraph 1 be construed

so as to impose on a Contracting State the obligation:

a) to carry out administrative measures at variance with the

laws and administrative practice of that or of the other

Contracting State;

b) to supply information which is not obtainable under the

laws or in the normal course of the administration of that or of

the other Contracting State;

c) to supply information which would disclose any trade,

business, industrial, commercial or professional secret or trade

process, or information, the disclosure of which would be

contrary to public policy (ordre public).

Article 31

MISCELLANEOUS RULES

The provisions of this Convention shall not be construed to

restrict in any manner any exemption, deduction, credit or other

allowance accorded:

a) by the laws of a Contracting State in the determination of

the tax imposed by that State; or

b) by any other agreement between the Contracting States or

between one Contracting State and a resident of the other

Contracting State.

Article 32

MEMBERS OF DIPLOMATIC MISSIONS AND CONSULAR POSTS

Nothing in this Convention shall affect the fiscal privileges

of members of diplomatic missions or consular posts under the

general rules of international law or under the provisions of

special agreements.

Article 33

ENTRY INTO FORCE

1. The Governments of the Contracting States shall notify each

other in writing through diplomatic channels when the

constitutional requirements for the entry into force of this

Convention have been complied with.

2. The Convention shall enter into force on the date of the

later of the notifications referred to in paragraph 1 and its

provisions shall have effect in both Contracting States:

a) in respect of taxes withheld at source, on income derived

on or after the first day of January in the calendar year next

following the year in which the Convention enters into force;

b) in respect of other taxes on income and taxes on capital,

for taxes chargeable for any fiscal year beginning on or after

the first day of January in the calendar year next following the

year in which the Convention enters into force.

Article 34

TERMINATION

This Convention shall remain in force indefinitely until

terminated by a Contracting State. Either Contracting State may

terminate the Convention, through diplomatic channels, by giving

written notice of termination at least six months before the end

of any calendar year following after the period of five years

from the year in which the provisions of the Convention became

effective. In such event, the Convention shall cease to have

effect in both Contracting States:

a) in respect of taxes withheld at source, on income derived

on or after the first day of January in the calendar year next

following the year in which the notice has been given;

b) in respect of other taxes on income and taxes on capital,

for taxes chargeable for any fiscal year beginning on or after

the first day of January in the calendar year next following the

year in which the notice has been given.

In witness whereof, the undersigned, duly authorised thereto,

have signed this Convention.

Done at Abu Dhabi this 11th day of March 2012, in

two originals, in the Latvian, Arabic and English languages, all

three texts being equally authentic. In the case of divergence of

interpretation, the English text shall prevail.

For the Government

of the Republic of Latvia

For the Government

the United Arab Emirates

Māris Selga

Ebeid Hamid El-Tayer

Ambassador

Extraordinary and Plenipotentiary of the Republic of Latvia

in the United Arab Emirates

Minister of State

for Financial Affairs

PROTOCOL

At the signing of the Convention between the Government of the

Republic of Latvia and the Government of the United Arab Emirates

for the avoidance of double taxation and the prevention of fiscal

evasion with respect to taxes on income and on capital

(hereinafter referred to as "the Convention") the

undersigned have agreed upon the following provisions which form

an integral part of the Convention.

1. With reference to paragraph 1 of Article 2.

It is understood that the United Arab Emirates consists

of:

− the federal State composed of the seven Emirates,

− the local governments of the federal State (Emirate of Abu

Dhabi, Emirate of Dubai, Emirate of Sharjah, Emirate of Ajman,

Emirate of Umm Al-Qaiwain, Emirate of Ras al-Kaimah and Emirate

of Fujairah), and

− the local authorities of the local governments.

2. With reference to subparagraph c) of paragraph 2 of Article

4.

It is understood that in the case of the United Arab Emirates

a governmental institution defined in subparagraph c) of

paragraph 2 of Article 4 shall include the Abu Dhabi Investment

Authority, the Abu Dhabi Investment Council, Mubadala Development

Company (Mubadala), Dubai World, Dubai Investments Company (DIC),

UAE Investment Authority and International Petroleum Investment

Company (IPIC).

3. With reference to paragraph 3 of Article 7:

It is understood that conditions for the deductibility of

expenses are a matter to be determined by the domestic law of the

Contracting State in which the permanent establishment is

situated, subject to the provisions of Article 28, in particular,

paragraphs 3 and 4.

4. With reference to paragraph 1 of Article 8:

It is understood that the term "profits"

includes:

− profits, net profits, gross receipts and revenues derived

directly from the operation of ships or aircraft in international

traffic;

− interest on sums generated directly from the operation of

ships or aircraft in international traffic which is incidental to

such operation;

− income from the sale of tickets on behalf of an enterprise

operating ships or aircraft in international traffic;

− income from rendering of engineering services and any other

income arising from other technical services if such services are

incidental to the operation aircraft in international

traffic.

5. With reference to paragraph 3 of Article 11:

If the Government of a Contracting State participates in a

loan indirectly through an agent or otherwise, the exemption

provided for in paragraph 3 shall apply proportionally to the

participation of that Government in such a loan. The

participation shall be evidenced by a certificate issued by the

competent authority of that Contracting State.

6. With reference to Article 13:

It is understood that paragraph 5 includes capital gains from

the alienation of shares or other comparable interest, other than

those referred to in paragraph 2, derived by a resident of a

Contracting State, including the governmental institutions or

investment companies of that State, and such gains shall be

taxable only in the State of which the alienator is a

resident.

7. With reference to Article 30:

If information is requested by a Contracting State in

accordance with this Article, the other Contracting State shall

obtain the information to which the request relates, including

information held by a bank, other financial institution, nominee

or person acting in an agency or a fiduciary capacity, in the

same manner and to the same extent as if the tax of the

first-mentioned State were the tax of that other State and were

being imposed by that other State, even though that other State

may not need such information for its own tax purposes.

In witness whereof, the undersigned, duly authorised thereto,

have signed this Protocol.

Done at Abu Dhabi this 11th day of March 2012, in

two originals, in the Latvian, Arabic and English languages, all

three texts being equally authentic. In the case of divergence of

interpretation, the English text shall prevail.

For

the Government of the Republic of Latvia

For

the Government of the United Arab Emirates

Māris Selga

Ebeid Hamid El-Tayer

Ambassador Extraordinary and Plenipotentiary of the Republic

of Latvia in the United Arab Emirates

Minister of State for Financial Affairs