International Tax

Non-resident companies and foreign groups with UAE activities face UAE Corporate Tax & VAT registration requirements, FTA filing obligations and Ultimate Beneficial Ownership disclosure, even where they have no Permanent Establishment. We advise on the scope of these obligations for each type of UAE-facing activity, manage the registration and filing process with the relevant authorities, and flag where the activity crosses a line into taxable presence or reporting obligation.

The UAE has concluded over 130 Double Taxation Agreements and these treaty benefits are not automatic. We help clients secure Tax Residency Certificates from the Federal Tax Authority, build the substance file that supports a treaty claim, and apply the correct treaty to specific income flows including dividends, interest, royalties, capital gains and business profits. Where a treaty claim is challenged in the other jurisdiction, we coordinate with local counsel.

We perform Permanent Establishment (PE) assessments under the UAE Corporate Tax Law and relevant tax treaties, covering risks related to fixed place of business, dependent agents, or service PE thresholds. For UAE businesses operating internationally, we evaluate cross-border activities to identify potential PE exposure and support alignment of operational structures with applicable tax and regulatory frameworks to mitigate unintended tax risks.

Transfer pricing policy design and documentation aligned with Article 34 of the UAE Corporate Tax Law and the OECD Transfer Pricing Guidelines. We cover the Master File and Local File where applicable thresholds are met, benchmarking studies, intercompany agreements and the related party disclosure form. For groups with global TP policies already in place, we test UAE compliance against those policies and flag where local documentation falls short. We also provide support in drafting and filing Advance Pricing Agreements (APA) with the FTA.

The UAE implemented the OECD Pillar 2 Global Minimum Tax through Cabinet Decision No. 142 of 2024, applying a Domestic Minimum Top-up Tax to MNE groups with annual consolidated revenue of EUR 750 million or more, effective for financial years starting on or after 1 January 2025. We assess scope, provide support in registration with FTA, run Effective Tax Rate computations and identify where UAE entity-level decisions affect group top-up exposure.

While the UAE generally does not levy domestic withholding tax on outbound payments, cross-border transactions may be subject to withholding taxes in the source jurisdiction. We assess applicable tax treaty provisions and domestic laws to determine the appropriate withholding tax outcomes. Our approach focuses on ensuring that cross-border arrangements are aligned with applicable legal requirements, including treaty eligibility conditions such as beneficial ownership and substance.

We assist in evaluating the availability and utilization of foreign tax credits in cross-border transactions involving UAE businesses and cross-border employees. This includes analysis of domestic tax laws, applicable tax treaties, and Multilateral Instrument provisions. Our focus is on determining eligibility in line with substance, and ensuring positions are appropriately supported and compliant with regulatory requirement.

Pre-immigration tax planning for founders and HNIs relocating to or from the UAE - residency transitions, exit tax exposure in the origin country, asset realignment, and ESOP and RSU positioning around the move. For corporate clients, secondment structuring and cross-border employee mobility, including PE risk from senior executive presence and home and host country tax compliance.