International Tax Planning

The Ministry of Finance states that the UAE has concluded 137 double taxation agreements with most of its major trading partners, and 193 agreements in total when bilateral investment treaties are counted. The agreements aim to exempt or reduce taxes on income and profits, eliminate double taxation and prevent fiscal evasion. To use a treaty, your UAE company or you personally will usually need a Tax Residency Certificate issued by the FTA for the relevant period, and the other state may ask for its own form to be stamped. We check the specific treaty text before a structure is built, because rates and anti-abuse clauses differ from treaty to treaty, and we obtain the certificates each year.

Source: Ministry of Finance — Double Taxation Agreements (DTAs) (accessed 24 October 2026)

Through EmaraTax. The FTA's Tax Resident and Tax Residency Certificate guide sets out the process: log in, choose Tax Residency Certificate under other services, select your corporate tax registration number (or none), state whether the certificate is for a treaty, upload the supporting documents and pay. The submission fee is AED 50; the processing fee after approval is AED 500 for a corporate tax registrant, AED 1,000 for a natural person without a registration number and AED 1,750 for a company without one, plus AED 250 per hard copy. The FTA generally responds within 10 business days. A certificate covers at most 12 months, cannot be issued for a future period, and a new company must have existed for 12 months before applying. We assemble the evidence and file.

Source: Federal Tax Authority — Tax Procedures Guide – Tax Resident and Tax Residency Certificate (TPGTR1) (accessed 24 October 2026)

Under Cabinet Decision No. 85 of 2022, a natural person is a UAE tax resident if any one of three tests is met in the relevant 12 consecutive months: physical presence of 183 days or more; physical presence of 90 days or more combined with UAE or GCC nationality or a valid UAE residence permit and either a permanent place of residence in the UAE or employment or a business here; or the UAE being the person's usual or primary place of residence and centre of financial and personal interests. Days are calendar days. Meeting a test allows an application for a Tax Residency Certificate, which banks and foreign tax authorities increasingly ask for. We review travel records and residence evidence before you apply.

Source: Federal Tax Authority — Tax Procedures Guide – Tax Resident and Tax Residency Certificate (TPGTR1) (accessed 24 October 2026)

A company is a UAE resident person if it is incorporated, established or recognised in the UAE — including in a free zone — or if it is incorporated abroad but effectively managed and controlled in the UAE. Both tests sit in Article 11 of Federal Decree-Law No. 47 of 2022 and are mirrored in Cabinet Decision No. 85 of 2022. A resident company is taxed on its income from inside and outside the UAE, subject to the exemptions and credits the law provides. The effective-management test matters for foreign holding companies run from Dubai: board meetings and key decisions taken here can make the company a UAE taxpayer, with registration and filing obligations. We document where management actually happens before you rely on either outcome.

Source: Federal Tax Authority — Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses (accessed 24 October 2026)

No, not at present. Article 45 of Federal Decree-Law No. 47 of 2022 provides for withholding tax on specified UAE-sourced income of non-residents at 0% or such other rate as the Cabinet may set, and the Ministry of Finance confirms that the rate is currently 0%, so no tax is deducted from dividends, interest, royalties or service fees paid from the UAE to foreign shareholders or lenders. The relevance for structuring is usually on the other side: withholding imposed by the paying country on amounts coming into the UAE, which a treaty may reduce. We analyse the inbound withholding position and treaty eligibility for each cross-border flow before the structure is fixed.

Sources: Federal Tax Authority — Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses; Ministry of Finance — Corporate Tax FAQs (accessed 24 October 2026)

Usually not, if the participation exemption applies. Article 23 of Federal Decree-Law No. 47 of 2022 exempts income from a Participating Interest: a holding of 5% or more (or, per the Ministry of Finance, an acquisition value of at least AED 4,000,000) held, or intended to be held, for at least 12 months, in a company that is subject to tax of a similar character at a rate of not less than 9%, where the holding carries at least 5% of distributable profits and liquidation proceeds and no more than 50% of the subsidiary's assets are non-qualifying holdings. Dividends, capital gains and other income from the participation are then exempt. We test each holding against the conditions, particularly the subject-to-tax test for low-tax subsidiaries.

Sources: Federal Tax Authority — Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses; Ministry of Finance — Corporate Tax FAQs (accessed 24 October 2026)

Two ways. A resident company may elect under Article 24 of Federal Decree-Law No. 47 of 2022 to leave the income, expenditure and losses of its foreign permanent establishments out of its UAE taxable income altogether. Where no election is made and foreign income is taxed in the UAE, Article 47 allows a foreign tax credit for the foreign tax paid, capped at the UAE corporate tax due on that income; any unused credit cannot be carried forward or back, and records supporting the claim must be kept. The choice between the election and the credit is made case by case and depends on the branch's profit, loss and foreign rate. We model both routes before the first return in which the branch appears.

Source: Federal Tax Authority — Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses (accessed 24 October 2026)

Yes, for large multinational groups. Cabinet Decision No. 142 of 2024 imposes a Domestic Minimum Top-up Tax on UAE constituent entities of multinational groups with consolidated annual revenue of EUR 750 million or more in at least two of the four preceding fiscal years, for fiscal years beginning on or after 1 January 2025. The minimum rate is 15%, so a UAE entity whose effective rate falls below that — for example because of the 0% free zone regime — is topped up in the UAE rather than in the parent's country. The Ministry of Finance has decided not to implement the Income Inclusion Rule. Groups below the threshold are unaffected. We assess exposure for free zone subsidiaries of in-scope groups.

Sources: Federal Tax Authority — Cabinet Decision No. 142 of 2024 on the Imposition of Top-up Tax on Multinational Enterprises; Ministry of Finance — Top-up Tax (accessed 24 October 2026)