(i)Central Bank of the United Arab Emirates,
(ii)Emirates Investment Authority,
(iii) Abu Dhabi Investment Authority,
(iv)International Petroleum Investment Company (IPIC),
(v)Abu Dhabi Investment Council,
(vi)Investment Corporation of Dubai,
(vii)Abu Dhabi National Energy Company (TAQA),
(viii)Mubadala Development Company,
(ix)the Abu Dhabi Retirement Pensions and Benefits Fund,
(x)the General Pension and Social Security Authority,
and any other institutions directly or indirectly owned by either Contracting State that shall be agreed between the two Contracting States through exchange of letters.
(c)engaged in the active conduct of a trade or business in the first-mentioned State (other than the business of making or managing investments, unless these activities are banking or insurance activities carried on by a bank or insurance company) and the income derived from the other Contracting State is derived in connection with, or is incidental to, that trade or business;
(d)a company in whose principal class of shares there is a substantial and regular trading on a recognized securities exchange, or which is wholly owned, directly or indirectly, by a resident of that Contracting State in whose principal class of shares there is substantial and regular trading on a recognized securities exchange;
(e)an entity that is a not-for-profit organization (including a private foundation) and that, by virtue of that status, is generally recognized and exempt from income taxation in its Contracting State of residence, provided that more than half of the beneficiaries, members or participants, if any, in such organization are entitled, under this Article, to the benefits of this Convention; or
(f)a person that satisfies both of the following conditions:
(i)more than 50% of the beneficial interest in such person (or in the case of a company, more than 50% of the number of shares of each class of the company's shares) is owned, directly or indirectly, by persons entitled to the benefits of this Convention under subparagraphs (a), (b), (d) or (e); and
(ii)not more than 50% of the gross income of such person is used directly or indirectly, to meet liabilities (including liabilities for interest or royalties) to persons not entitled to the benefits of this Convention under subparagraph (a), (b), (d) or (e).