Valuation Apartment Al Ain

What a valuation of an Al Ain apartment is really measuring

Valuing an apartment in Al Ain means putting a figure on a property in an Abu Dhabi emirate market where apartment sales are relatively few, where most buildings are let and where the legal status of the property decides who is able to acquire it next. This guide is written for the owner who wants to know what their apartment is worth before selling, keeping it, refinancing, dividing an estate or insuring it, whether they live in the Emirates or manage the property from abroad. It explains how a credible value is built: comparables by district, prices per square metre in dirhams, the role of the licensed valuer and the bank, the costs that are deducted and the limits of any headline figure.

Written by the ting.ad editorial team 2026-08-26

Al Ain in Street View: drag to look around.

These two readings of the same property do not carry the same weight depending on what you intend to do with the figure, and that use is what you need to identify first.

The owner of an apartment in Al Ain often thinks of its value in terms of what they paid, the rent they collect or the prices shown on property portals. A serious valuation measures something else: the price that a buyer entitled to hold this property would pay today, given comparable sales, the status of the title and the condition of the building. Yet apartment sales are relatively rare in the city, where a large share of the stock belongs to owners of whole buildings who let rather than sell. Every figure therefore rests on few comparables and deserves to be read as a range rather than an exact amount. The three contrasts below sum up the gap between the value people imagine and the value a market can confirm.

The asking price of comparable apartments on the portalsThe price at which comparable apartments actually changed hands
A listing reflects a seller's hopes, not an agreement between two parties, and some stay online for months without finding a taker. Valuers and banks rely on registered transactions, which are often lower than asking prices. Your valuation should start from those completed sales and use listings only as an indication of the competition.
The value in use of a large family apartment in a quiet cityThe resale value in a market dominated by renting
Al Ain's generous floor areas and green setting make everyday life pleasant, but that comfort does not translate automatically into price. Many potential buyers are investors who reduce every property to its rent and its service charges. A realistic valuation must therefore take account of what the property would earn, not only what it offers its occupant.
The price paid when you yourself acquired the apartmentThe value the market recognises on the date of the valuation
The amount on your deed does not bind today's market, which may have moved up or down since. The age of the building, wear on the equipment and the arrival of newer developments in the district also change where your property sits among the comparables. Treating that original price as a floor is one of the most common valuation mistakes.

Which reading of value fits what you plan to do with your Al Ain apartment?

Whatever you need the figure for, a valuation carried out from abroad follows habits that first have to be unlearnt.

The same apartment in Al Ain can be given several equally valid values depending on the question being asked. The owner preparing a sale is looking for a market price that will hold up in front of buyers, the owner refinancing needs the figure a bank will accept, and the heir dividing an estate wants a value everyone will agree on. Confusing these readings leads to an unrealistic asking price, a smaller loan than expected or a contested division. Identifying yours before approaching anyone lets you choose the right adviser and the right method.

The owner preparing to go to market

You need a market value, meaning the price an eligible buyer would pay within a reasonable time. Start with recent sales in your building or in developments of the same generation in Al Ain, then adjust for floor, view, condition and service charges. Ask several agents for price opinions, bearing in mind that the highest is not necessarily the most realistic. If the property is let, value it separately with vacant possession and with the tenant in place, because the two appeal to different buyers.

The owner who keeps and finances

The figure that matters is the one the valuer appointed by the bank will accept, because that is what the amount the bank will lend is calculated on. This value is deliberately cautious and relies on verifiable transactions rather than listings. Prepare the title deed, the floor plan, the service charge statement and, where relevant, the registered lease to avoid a low valuation for lack of documents. For insurance, work from the cost of reinstating the home rather than its market value, which includes an element of land and location.

The owner who has to share out a value

You need a figure that several parties, sometimes under the jurisdictions of two countries, will accept without dispute. A written report from a licensed valuer, dated and supported by comparables, carries far more weight than an agent's opinion or an average found online. If heirs or a lawyer in another country are involved, plan ahead for conversion into another currency on a specific date and for how the value will be declared on each side. Have the approach checked by a legal adviser in the Emirates and by your adviser at home before fixing the figure.

Valuing an apartment in Al Ain from abroad: what works differently

The mudbrick towers of Al Jahili Fort in Al Ain under a clear sky — Photo: Jeff2rado · CC BY-SA 4.0 · Wikimedia Commons

With these differences in mind, the first practical question is still which area provides your comparables.

An owner used to a European market arrives with tools and habits that do not carry over unchanged to Al Ain. Price sources, the way floor area is measured, the role of each professional and even the question of who is allowed to acquire the property differ markedly. These differences do not make the valuation more of a gamble, but they do require every assumption to be checked rather than imported. The four contrasts below are the ones that most often change the final figure.

From abroad

Past sale prices freely searchable in a public transaction database

Al Ain

Transaction data centralised by the emirate's authorities, but less open to the general public and thin for Al Ain apartments

You will often have to go through an agent, a valuer or the official services to obtain reliable comparables, rather than looking them up yourself in a few minutes.

From abroad

A floor area defined by law and stated in every sale of a unit in a shared building

Al Ain

Advertised areas that may include balconies or outdoor space depending on how the seller chooses to present them

Compare prices per square metre on the area recorded on the title or official plan, otherwise two apparently similar properties are not being measured in the same way.

From abroad

A price opinion given by an agent or a lawyer, often free and informal

Al Ain

A clear distinction between an agent's price opinion and a licensed valuer's report, often required by the bank

For a mortgage, a division of assets or any official procedure, only the valuer's report will count; the agent's opinion mainly serves to set an asking price.

From abroad

A property that any buyer can acquire, whatever their nationality

Al Ain

A property whose legal status and zone determine which buyers are allowed to hold it

The narrower the circle of eligible buyers, the more the value and speed of resale are affected; check this point before making any comparison.

Which Al Ain district sets the comparables for your apartment?

Once the reference area is identified, the price levels that serve as benchmarks for value can be read.

In Al Ain the district matters, but the building and its generation often matter more, because apartments are concentrated in a few areas with very different profiles. A credible valuation compares your property first with apartments in the same building, then with neighbouring developments of the same age and standard. When such comparables are missing, the valuer widens the search and the margin of uncertainty grows accordingly. The three areas below show how location shapes the reading of value.

Al Jimi

A busy commercial area, sought after by buyers and tenants who want shops, healthcare and the main roads close at hand.

Suits: Apartments in well-maintained buildings, whose value rests on steady rental demand and on a larger number of comparables than elsewhere.
Trade-off: Buildings of very different ages sit side by side, so a district average can overstate an older property or understate a recent development.

Al Muwaiji

A more residential and peaceful district, appreciated for its family atmosphere and quiet streets.

Suits: Large family apartments, whose value depends on space, calm and the quality of the surroundings more than on proximity to shops.
Trade-off: Apartment sales are less frequent here, which often forces the valuer to look for references in other areas and widens the range.

The city centre

A dense urban core close to the oasis, offices and government services, where apartment buildings follow one after another.

Suits: Small and medium-sized units intended for letting, whose value is read first and foremost through the rent they produce.
Trade-off: The stock is often older, and the condition of common areas, parking and air conditioning can make value vary from one building to the next.

What is an apartment in Al Ain worth today?

These benchmarks only hold for a property with a comparable status, which means looking closely at what you actually hold.

The available benchmarks put the median price of an apartment in Al Ain at around AED 800,000, with an average price close to AED 912,000, a median price per square metre of AED 7,125 and an average size of about 110 m². These figures are estimates built from listings: they describe the level at which comparable properties are offered, not the price at which they sold, and should be read as the probable top of a range. The breakdown by number of bedrooms is more useful than an overall average, because the price per square metre falls as size increases, from about AED 8,100 for one bedroom to AED 7,125 for three or four. To value your apartment, find the line that matches its layout, then adjust for the building, floor, condition and title status. Finally, test that benchmark against the registered transactions a valuer can provide before treating it as the value of your property.

Al Ain For sale Apartment estimate

Median price / m² AED 7,125 Half the apartments sell below this

Median price AED 800k the average is 14% higher — a few very large properties pull it up

Most common 2 bedrooms 38 % of listings

Average size 110 m²

By number of bedrooms

Bedrooms	Share of market	Avg price	Price / m²	Avg size
1	30 %	AED 608k	AED 8,100 +8 %	75 m²
2 most common	38 %	AED 825k	AED 7,500	110 m²
3	22 %	AED 1.07m	AED 7,125 best value / m²	150 m²
4	10 %	AED 1.5m	AED 7,125 best value / m²	210 m²

Each row is an average, compared against the area average of AED 7,500 / m². These are indicative estimates of a typical local market, not a measured sample of live listings. Check current listings before relying on them.

What you actually hold in Al Ain, and what that does to value

Before treating any figure as settled, one simple rule separates a price opinion from a verified value.

In the Emirate of Abu Dhabi, two identical apartments can be worth different amounts because they do not confer the same rights. The law distinguishes freehold ownership, open to foreigners in designated zones, from long-term rights whose scope and expiry are set by contract. That status determines who can acquire the property next, how long it will hold its value and which banks will agree to lend against it. It must therefore be checked on the title before any comparison, because a comparable with a different status distorts the valuation.

Freehold ownership in a zone open to foreigners

When the apartment is held freehold in a zone where the emirate's law allows foreign ownership, it can be resold to a wide range of buyers, residents and non-residents alike. That liquidity supports its value and makes it easier for the next buyer to obtain bank finance. It still needs to be confirmed that the zone is among those designated by the authorities, because the list and its boundaries are a matter for the emirate's regulations.

What it changesYour property can be compared with the broadest set of sales in the market, and its value holds up in front of a large pool of buyers.

A long-term right or a property outside a designated zone

Outside designated zones, or for certain developments, the rights granted take the form of long-term rights, such as usufruct or musataha, with an expiry date written into the contract. The value of these rights declines as the remaining term shortens, and the circle of buyers or banks willing to commit may be narrower. In some cases only certain nationalities may hold the property freehold, which limits demand still further.

What it changesYour valuation must reflect the remaining term and the eligible buyers; comparing this property with freehold sales would overvalue it.

The rule to know before treating any Al Ain figure as settled

What remains is to see, in order, who takes part in building the figure and when each of them moves it.

A figure only becomes a value when it rests on verifiable evidence: a title whose status is confirmed, comparables that actually sold and a building whose accounts are known. In Al Ain, where apartment transactions are few, it is tempting to rely on an asking price or an average found online. Every missing link adds uncertainty that will be paid for later, during a negotiation, a mortgage application or a division of assets. The chain below shows the checks that turn a price opinion into a value you can defend.

You have a first figure for your apartment in Al Ain, obtained from an agent, a portal or an acquaintance.
Check the title deed and the exact status of the property, freehold or long-term right, with the emirate's land services.
Replace asking prices with recent registered transactions, in the same building or in developments of the same generation and district.
Obtain from the building manager the level of service charges, confirmation of no arrears and any planned works, which determine the no-objection certificate.
Adjust the comparables for the area recorded on the title, the floor, the condition of the air conditioning and the current lease and, where necessary, have the whole exercise confirmed by a licensed valuer.
You hold a documented value range that you can defend in front of a buyer, a bank or co-heirs.

How the value of an apartment in Al Ain is built, step by step

Valuing an apartment in Al Ain is not the work of a single person but a series of steps in which each party contributes a piece of the puzzle. The owner gathers the documents, the agent reads the competition, the valuer applies a method, the bank settles on its own figure and the official registers confirm status and past sales. Knowing this sequence tells you when the figure can still move and which document will move it. Depending on the purpose, you will not always need every step, but none should be skipped by accident.

You, the owner Gather the title, the plan, the service charges and any lease You bring together the title deed, the floor plan with the official area, the service charge statement and, if the property is let, the registered lease. These documents stop a valuer or an agent from working on assumptions and settling on a cautious figure for lack of evidence.
The estate agent A price opinion based on the competition and recent sales The agent positions your apartment among the properties on the market and those that have recently sold in the area. Their opinion is useful for setting an asking price, but it remains a commercial view that needs to be tested against other sources.
The licensed valuer Inspection, analysis of comparables and valuation report The valuer inspects the property, checks the area and condition, selects comparable transactions and, for a let property, tests that approach against an income-based value. They deliver a dated, reasoned report that serves as the reference for a bank, a division of assets or legal proceedings.
The bank The value accepted for lending When a mortgage is involved, the bank adopts its valuer's figure and applies the lending caps set by the Central Bank of the UAE. That figure, often below the hoped-for price, determines what the buyer or you yourself will be able to borrow.
The emirate's land services Confirmation of status and reference transactions The services of the Department of Municipalities and Transport and the DARI platform make it possible to check the title, the rights attached to the property and the registration of transactions. This is the stage at which the figure is anchored in official facts rather than statements.

Apartment or villa in Al Ain: how each type of property holds its value

The type of property explains how value is formed; what remains is to know which price levels to compare yours with and what will be deducted.

In Al Ain, the villa remains the cultural reference for a family home, and that preference shapes how apartments are valued. A villa draws a large part of its value from the land, the private courtyard and the scope to extend or renovate, which makes it less sensitive to wear on the building. An apartment, by contrast, owns only a share of a building: its value depends closely on the condition of the common areas, the quality of the building's management and the age of shared equipment, air conditioning and lifts first among them. When a building ages without works, the apartment loses value even if the interior has been carefully renovated.

The two types of property do not appeal to the same buyers either, and it is those buyers who set the comparables. Apartments in central areas such as Al Jimi or the city centre mainly attract investors who let them to working professionals, teachers or healthcare staff; their value is then read largely through the rent and the service charges. Villas in more residential districts attract families who intend to live in them and who pay for space and privacy. Valuing an apartment by comparing it with a villa, even on a per-square-metre basis, almost always leads to an error, because the two markets do not respond to the same arguments.

In practice, an apartment in Al Ain holds its value when it combines a well-run building, service charges in proportion to the services provided, a title that allows it to be resold to a wide range of buyers and solid rental demand in the district. It loses value faster than a villa when one of those pillars weakens, for example a building in debt or a right whose term is running down. For a reliable valuation, compare apartment with apartment, in buildings of the same generation, and treat the value of neighbouring villas as background only. If you are torn between keeping and selling, watch above all the condition of the building and the trend in rents, which often signal movements in value before asking prices do.

Which price levels should you measure your Al Ain apartment against, and which costs are deducted?

With these figures in place, it remains to understand what a buyer is really paying for day to day when they choose one apartment over another.

A useful valuation compares your apartment with the right category of property, then separates its market value from the sum you would actually receive. The first table sets out average benchmarks by number of bedrooms, which come from listings and should be adjusted downwards where registered transactions are lower. The second lists the costs that do not change the value of the property but reduce the net amount from a sale or a refinancing. The ranges shown are orders of magnitude, partly negotiable, and must be confirmed by quotes, by your bank and by the emirate's services.

Average price benchmarks by apartment layout in Al Ain (estimates drawn from listings)
Layout and average size	Average price and reference price per m²	What to check before comparing yourself with it
One bedroom, about 75 m²	About AED 607,500, or roughly AED 8,100/m²	The price per square metre is at its highest; check that your property's area is measured in the same way as the listings and that the building is of the same generation.
Two bedrooms, about 110 m²	About AED 825,000, or roughly AED 7,500/m²	The category with the most listings, and therefore the most reliable for comparison; adjust for floor, parking and the condition of the air conditioning.
Three bedrooms, about 150 m²	About AED 1,068,750, or roughly AED 7,125/m²	Comparables become scarcer; the quality of the development and the calm of the district count for more than the average per square metre.
Four bedrooms, about 210 m²	About AED 1,496,250, or roughly AED 7,125/m²	Few comparable properties and a narrower pool of buyers; the valuation range is wide and a valuer's report is strongly recommended.

These averages describe asking prices, not completed sales; they take no account of title status, the age of the building or any lease, each of which can move the value of your apartment significantly.

Costs to deduct from the value to find the net amount from a sale or refinancing
Item	Order of magnitude or mechanism	Effect on your calculation
Estate agent's commission	Often in the region of 1 to 2% of the price, to be negotiated before signing the agency agreement	Directly reduces the amount received; check whether VAT is added and what remains payable if the property does not sell.
Registration and transfer fees	In the region of 2% of the price, collected by the emirate's land services, with the split agreed between the parties	They are frequently borne by the buyer, who then factors them into the price they will pay; confirm the current scale with the DMT.
Valuation, no-objection certificate and mortgage redemption	Valuer's fees and certificate charges on quotation; early settlement fees regulated by banking rules	Service charge arrears and the outstanding loan are deducted before the funds reach you; ask your bank and the building manager for a statement.

The Emirates do not currently tax an individual's gain on a home; an owner who is tax resident elsewhere should, however, check how that gain is treated in their country of residence and allow for the cost of currency exchange when repatriating the funds.

Healthcare, schools, commutes: the ordinary Tuesday a buyer pays for in Al Ain

These visible strengths do not tell the whole story: some details that are decisive for value appear in no headline figure.

A buyer does not pay for abstract square metres but for the day they will live from this apartment, or the day their tenant will. In Al Ain, a city organised around the car, value is formed largely through travel times to schools, hospitals, shopping centres and workplaces. An apartment that makes that daily routine simple lets more easily, resells faster and justifies a price closer to the top of the range. The typical day below shows the points that the valuer and the buyer examine, often without saying so.

07:00 The apartment, in a residential building in Al Jimi or Al Muwaiji A covered parking space, a reliable lift and quiet air conditioning are part of what the occupant experiences from the moment they wake up. They are also points the valuer notes during the inspection, and they distinguish two apartments of identical size.
07:45 A school in the area For a family, being close to well-regarded schools weighs heavily in the choice of home. An apartment a few minutes from sought-after schools holds its value better and finds a tenant or buyer more quickly.
08:30 Workplace, government office or the United Arab Emirates University campus The city's major employers, including the university, the hospitals and public services, sustain steady rental demand. A short commute to these hubs supports the rent the property can earn, and therefore its income-based value.
13:00 A nearby shopping centre, such as Al Jimi Mall or Bawadi Mall In a city where people shop in large air-conditioned centres, quick access to a mall is a concrete selling point. It matters more for an apartment, whose occupants look for convenience, than for a villa on the outskirts.
17:30 Parks, the Al Ain Oasis and early-evening walks The city's green setting is one of its recognised strengths, and proximity to a park or the oasis improves a district's appeal. That advantage shows up more in the speed of resale, however, than in a precisely measurable price difference.
19:30 The local hospital or clinic The presence of large healthcare facilities in the city attracts medical staff looking for apartments close to work. For a property intended for letting, this steady clientele is an element of value that the valuer can take into account.

What a headline figure will never tell you about your Al Ain apartment

Overlooking these details produces valuation errors that are often discovered only after acting on the figure.

Average prices per square metre summarise a market, but they erase precisely what sets your apartment apart from its neighbours. In Al Ain, several technical, legal and financial factors can shift value by several per cent without appearing in any listing. An informed buyer or a valuer will uncover them during the viewing or when reviewing the documents. Knowing them in advance lets you adjust your valuation rather than see it challenged at the negotiating stage.

The age and billing arrangement of the air conditioning: An old central system or an individual unit at the end of its life signals replacement costs and high bills during the hot months. The buyer or valuer deducts the likely cost, and the billing arrangement, individual or shared, also changes the comparison between two apartments.
The floor area actually recorded on the title or official plan: If the advertised area includes balconies or outdoor space while that of the comparables does not, the price per square metre is distorted. A difference of a few square metres on a mid-sized apartment is enough to shift the valuation by tens of thousands of dirhams.
The zone and legal status of the property: An apartment outside the zones open to foreigners, or held under a right of limited duration, does not appeal to the same buyers as a freehold property. Comparing it with sales of a different status overstates its value and its liquidity.
The current lease and the rent actually received: A sitting tenant paying below-market rent, or a lease that cannot be ended quickly, weighs on value for an owner-occupier buyer. Conversely, a registered lease at a market rent reassures an investor and supports an income-based value.
The financial health and plans of the building's owners' association: Service charge arrears, an inadequate reserve fund or major works announced on the lifts, roof or central air conditioning will be charged to the owners. An informed buyer subtracts them from the price, and a building in debt can delay the certificate needed for the sale.

The Al Ain valuation mistakes that only surface six months later

These mistakes also show that, for some owners, acting on a valuation right now is simply not the right choice.

Looked likeA price set from the highest listings in the building, taken to be representative of the market.

Turned outThose listings had never found a taker, and the apartment stayed online for months before selling well below, after several successive price cuts.

Would have caught itHaving the valuation based on recent registered transactions and treating listings only as a snapshot of the competition.
Looked likeA value calculated by multiplying the advertised area by the district's average price per square metre.

Turned outThe area included a large balcony that the comparables did not have, and the bank's valuer settled on a much lower figure, reducing the planned refinancing.

Would have caught itWorking from the area recorded on the title and comparing properties measured in the same way, in buildings of the same generation.
Looked likeAn apartment compared without caution with sales of freehold properties in another zone.

Turned outThe property had a status open to a narrower pool of buyers, and interested parties negotiated accordingly, well below the initial valuation.

Would have caught itChecking the exact title status and zone with the emirate's land services before accepting any comparable.
Looked likeAn estate value fixed quickly from an agent's opinion, to speed up the division.

Turned outA co-heir disputed the figure for lack of a reasoned report, and a formal valuation had to be commissioned, delaying the division and adding costs.

Would have caught itCommissioning from the outset a written report from a licensed valuer, dated and based on comparables, accepted by all parties.

Who should not act on an Al Ain apartment valuation right now?

With these cases set aside, it remains to judge how much confidence the figure in your hands deserves.

A valuation commits you to nothing: it informs a decision, but it can also push you to act too early or on the wrong basis. In Al Ain, where comparables are scarce and legal status matters as much as price, some situations call for patience rather than an immediate sale, refinancing or division. The profiles below often gain by waiting, completing their file or changing method before relying on a figure. Recognising them keeps a fragile valuation from turning into a costly decision.

The owner whose valuation rests solely on online listings

Have a value established from registered transactions before setting a price or negotiating.

In a market with few apartment sales, a figure drawn from listings often overstates value and exposes the owner to a listing that drags on or to a smaller refinancing than expected.
The owner whose title status or zone has not yet been checked

Obtain confirmation of the exact status from the emirate's land services before any decision.

A property held under a right of limited duration or outside a zone open to foreigners is not worth the same as a freehold property, and a decision made on a wrong assumption is hard to reverse.
The landlord whose tenant is in place on a recently renewed lease

Value the property separately with the tenant in place and with vacant possession, then weigh the timing of a sale against the lease expiry.

Selling mid-lease limits the market to investors, who negotiate on yield, whereas a vacant sale can also reach owner-occupiers and sometimes achieve more.
Heirs or former spouses who do not yet agree on the method

First agree on a shared licensed valuer and a valuation date, before discussing the amount.

A figure produced by one party alone will almost always be disputed, and a formal valuation commissioned late costs more in fees and delays than a joint approach from the start.

So how much confidence should you place in the figure you hold for your Al Ain apartment?

To round off this reading, the answers to the frequently asked questions below return to the practical points of valuation.

A figure deserves your confidence when it stands up to three simple questions. Does it rest on transactions that were actually registered rather than on asking prices? Does it take account of the exact status of your title, the zone and the buyers entitled to acquire the property? Does it reflect what sets your apartment apart from the average: the area recorded on the title, the floor, the condition of the air conditioning, the building's accounts and the current lease? If the answer to each is yes, you hold a value you can defend; if one is missing, you still hold a price opinion.

In Al Ain, caution is even more warranted than elsewhere, because the small number of apartment sales naturally widens the range. The available benchmarks, around AED 800,000 as a median price and AED 7,125 to 8,100 per square metre depending on size, describe the level of properties on offer; they replace neither an inspection, nor a selection of comparables, nor a reading of the title. Rather than a single amount, work with a range, identify what could place you at the top or bottom of it, and keep in mind the difference between market value and the net amount you would receive after commission, registration fees, service charges and repayment of the loan.

If you intend to sell, an agent's opinion tested against a few recent transactions may be enough to set a realistic asking price. If the figure is needed for a mortgage, an estate, a division of assets or a tax declaration in another country, commission a written report from a licensed valuer and have the property's status checked with the emirate's land services. In every case, date your valuation and update it before acting if the market or your building has changed. A well-built value does not guarantee a price, but it lets you decide with full knowledge of the facts, and keep or sell without regret.

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Sources

Abu Dhabi Department of Municipalities and Transport (DMT) The authority overseeing real estate in the emirate: land regulation, title registration and the supervision of professionals, including valuers.
DARI — the official real estate platform of the Emirate of Abu Dhabi Digital services for title deeds, transaction registration and property procedures across the emirate, Al Ain included.
Central Bank of the United Arab Emirates Rules applying to mortgages, including the lending caps measured against the property value accepted by the bank.
impots.gouv.fr — foreign-source income and gains How gains on a property located abroad are treated for French tax residents, and access to international tax treaties.