The Russia–UAE Tax Treaty from 1 January 2026: 10% on Dividends, Interest and Royalties, Residence, and What Actually Changes for Company Owners

From 1 January 2026, payments from Russia to the United Arab Emirates are subject to withholding tax capped at 10%, replacing the previous 15% on dividends and 25% on interest, royalties and certain services. The legal basis is the Agreement between the Government of the United Arab Emirates and the Government of the Russian Federation for the Elimination of Double Taxation with Respect to Taxes on Income and on Capital and the Prevention of Tax Evasion and Avoidance, signed on 17 February 2025 and in force since 18 July 2025. At the same time, the Russian Ministry of Finance removed the UAE from both of its “offshore” lists, and the narrow 2011 agreement ceased to have effect.

The principal risk. The reduced rate does not apply automatically. A Russian withholding agent must deduct tax at the domestic rate — 25% or 15% — unless it has received, before the date the income is paid, a UAE tax residency certificate issued for the purposes of an international agreement together with confirmation of beneficial ownership. If either document is missing at the moment of payment, tax is withheld in full, late-payment interest accrues and a penalty applies under Article 123 of the Russian Tax Code. Recovery then runs through the tax authority rather than through the counterparty.

The Legal Framework: Which Instruments Apply and from When

The framework consists of four layers: the treaty itself, the federal law ratifying it, Ministry of Finance orders on the offshore lists, and the Russian Tax Code provisions governing how relief is claimed.

The treaty. The Agreement was signed in Abu Dhabi on 17 February 2025 in two originals, each in Russian, Arabic and English. All three texts are equally authentic, but in the event of divergence in interpretation the English text prevails — this is stated expressly in the closing formulas of both the Agreement and the Protocol. The Protocol forms an integral part of the Agreement by virtue of Article 29.

Ratification. Russia ratified the Agreement by Federal Law No. 189-FZ of 7 July 2025 (official publication number 0001202507070009, published 7 July 2025).

Entry into force and the date of first application are two different dates, and conflating them is a costly mistake. Under Article 31, the Agreement enters into force on the date of the later of the two notifications of completion of domestic procedures, and applies from 1 January of the calendar year following the year of entry into force. The Russian Ministry of Finance Information Notice of 3 December 2025 records both dates: pursuant to note No. 16617-n-dbvsa of the Russian Ministry of Foreign Affairs dated 18 July 2025 and note No. 2/6/1-396 of the UAE Embassy dated 4 June 2025, the Agreement entered into force on 18 July 2025, and the date of first application is 1 January 2026.

The Agreement applies from 1 January 2026: to withholding taxes, on amounts paid or credited on or after 1 January 2026; to other taxes on income, for tax periods beginning on or after 1 January 2026.

Termination of the earlier treaty. Paragraph 2 of Article 31 terminates the Agreement between the Government of the Russian Federation and the Government of the United Arab Emirates on the Taxation of Income from Investments of the Contracting States and their Financial and Investment Institutions, signed on 7 December 2011, from the date the new Agreement takes effect — that is, from 1 January 2026.

The offshore lists. Order No. 187n of the Russian Ministry of Finance dated 22 December 2025 repealed item 38 of the List of Offshore Zones approved by Order No. 86n of 5 June 2023. Order No. 188n of the same date repealed item 20 of the Special List of Offshore Zones approved by Order No. 35n of 28 March 2024. Both orders were registered with the Ministry of Justice on 26 December 2025 (registration numbers 84815 and 84811), published on 29 December 2025 and apply to relations arising from 1 January 2026. In both lists, the repealed item reads “United Arab Emirates”.

Russian domestic provisions. Application of the Agreement is governed by Article 7 of the Russian Tax Code (primacy of treaties and the beneficial ownership concept), Articles 309 and 310 (Russian-source income and withholding agent duties), Article 312 (certificates of residence and beneficial ownership), Article 284 (domestic rates), Article 246.2 (corporate tax residence), Articles 25.13 and 25.13-1 (controlled foreign companies) and Articles 207, 208, 224 and 232 (personal income tax).

UAE domestic provisions. On the Emirati side the relevant instruments are Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses as amended (the consolidated text incorporates Federal Decree-Law No. 60 of 2023, No. 40 of 2024 and No. 28 of 2025), Cabinet Decision No. 116 of 2022 on the taxable income threshold, Cabinet Decision No. 100 of 2023 and Ministerial Decision No. 229 of 2025 on the free zone regime, Cabinet Decision No. 85 of 2022 on tax residency and Ministerial Decision No. 247 of 2023 on residency certificates for treaty purposes.

What the Russia–UAE Treaty Is and Who It Covers

A double tax treaty allocates between two states the right to tax the same item of income and caps the rate of tax withheld in the source state. A treaty neither creates nor abolishes a tax: it sets a ceiling on the domestic rate and prescribes relief mechanics.

Article 1 defines the persons covered. The Agreement applies to persons who are residents of one or both Contracting States. Paragraph 2 addresses income derived through fiscally transparent entities. Paragraph 3 contains a saving clause: each State retains the right to tax its own residents as if the Agreement did not exist, subject to the exceptions listed in that paragraph — paragraph 2 of Article 9, paragraph 3 of Article 16, paragraph 2 of Article 17, and Articles 18, 19, 20, 23, 24, 25 and 28.

The preamble sets the tone. The parties state their intention to eliminate double taxation “without creating opportunities for non-taxation or reduced taxation through tax evasion or avoidance (including through treaty-shopping arrangements aimed at obtaining reliefs provided in this Agreement for the indirect benefit of residents of third jurisdictions)”. That wording follows the BEPS minimum standard and warns plainly that the treaty is not designed for conduit structures.

The practical consequence for a business owner is that relief belongs not to a company registered in the UAE but to a company that is a UAE tax resident within the meaning of Article 4 and is the beneficial owner of the specific item of income. Free zone registration on its own proves neither. The differences between UAE jurisdictions are set out in Mainland vs Free Zone in 2026.

Which Taxes the Agreement Covers and Which It Does Not

Article 2 lists the taxes covered, and as at the date of signature the list is exhaustive: treaty relief cannot be claimed for a tax that does not appear in it. Paragraph 4 of Article 2 adds only taxes imposed after 17 February 2025 in addition to, or in place of, those listed.

On the UAE side the Agreement covers “the income tax” and “the corporate tax”, referred to collectively as “UAE tax”. On the Russian side it covers “the tax on profits of organizations”, “the tax on income of individuals”, “tax on property of enterprises” and “tax on property of individuals”, referred to as “Russian tax”.

Value added tax, social insurance contributions, customs duties and most non-tax levies fall outside the Agreement. A UAE company supplying electronic services to a Russian customer therefore obtains no VAT protection from the treaty: the Russian purchaser’s obligations as a VAT withholding agent remain in full.

Paragraph 2 of Article 2 defines taxes on income and on capital as 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, taxes on the total amounts of wages paid by enterprises, and taxes on capital appreciation.

Paragraph 4 extends the Agreement to identical or substantially similar taxes imposed after the date of signature in addition to, or in place of, existing taxes, and obliges the competent authorities to notify each other of significant changes to their tax laws within a reasonable time. The UAE Domestic Minimum Top-up Tax, introduced by Cabinet Decision No. 142 of 2024 for financial years beginning on or after 1 January 2025, raises a question of its own. It is not named in paragraph 3 of Article 2, and paragraph 4 reaches taxes imposed after the date of signature, whereas the Cabinet Decision was issued on 31 December 2024, some seven weeks before signature. The more robust characterisation is different: the charge is an overlay on UAE corporate tax and is therefore covered by “the corporate tax” in subparagraph (ii) of paragraph 3(a). Until the competent authorities address it, the point remains open, and it should be taken into account when computing the credit under Article 23.

The competent authorities are named in Article 3: for the UAE, the Ministry of Finance of the United Arab Emirates or its authorised representative; for Russia, the Ministry of Finance of the Russian Federation or its authorised representative. Mutual agreement requests go to them, not to local tax offices. ## Dividends: 10% with No Participation Threshold and a Single Exemption

Paragraph 1 of Article 10 caps the source State’s tax at ten per cent of the gross amount of the dividends, provided the beneficial owner is a resident of the other Contracting State.

The treaty wording is: “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 Contracting State, but if the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed 10% of the gross amount of the dividends.”

The rate is a single flat figure. Article 10 contains no second, lower tier for substantial holdings — no 5% rate at a 10% or 25% participation, and no minimum investment amount. That sets the UAE treaty apart from most of Russia’s tax treaties, where a two-tier scale is the norm. For an owner this simplifies the arithmetic: the size of the shareholding does not affect the rate.

The only exemption sits in paragraph 2: dividends arising in a Contracting State are exempt from tax in that State provided they are paid to the other Contracting State or its financial and investment institutions. The list of those institutions is set out in paragraph 1 of the Protocol, and it is not a closed one. On the UAE side it includes, among others, the Government of the UAE, the governments of the seven emirates, the Central Bank of the UAE, the Abu Dhabi Investment Authority, the Emirates Investment Authority, the Abu Dhabi Investment Council, Mubadala, the Abu Dhabi Developmental Holding Company, Dubai World, the Investment Corporation of Dubai, ADNOC, the Abu Dhabi Pension Fund, the General Pension and Social Security Authority and the UAE General Pension Fund. On the Russian side it includes the Government of the Russian Federation, the governments of the constituent regions, the Central Bank of the Russian Federation, the Pension and Social Insurance Fund of the Russian Federation, the Russian Direct Investment Fund, VEB.RF, Rostec, ROSNANO, Rosatom and Roscosmos.

Beyond the named institutions, paragraph 1 of the Protocol also covers any financial or investment organisation, institution, department, authority, agency, body or other entity established in the relevant State and wholly owned, directly or indirectly, by the government, and any entity wholly owned directly or indirectly by such an institution. The Protocol further allows the list to grow: entities whose capital is wholly owned by the State, its subdivisions or local authorities may be agreed from time to time by exchange of notes between the competent authorities, and the benefit applies to such an entity from the date on which it meets the ownership conditions.

A company that is private in form qualifies for the paragraph 2 exemption in one case only — where its capital is wholly owned, directly or indirectly, by the State or by an institution named in the Protocol. Partial state ownership, even a controlling stake, confers no right to the zero rate.

The definition of dividends in paragraph 4 is broader than everyday usage. It covers income from shares, including income from distributions of additional paid-in capital and reductions of charter capital, income from other rights that are not debt claims and that participate in profits, and other income, including income paid in the form of interest, which is subjected to the same taxation treatment as income from shares under the law of the State of the distributing company. That last limb catches the reclassification of interest as dividends under the Russian thin capitalisation rules in paragraph 4 of Article 269 of the Russian Tax Code: the reclassified amount stays within Article 10 and is capped at 10%.

The definition also covers distributions on units of collective investment vehicles but expressly excludes real estate funds and similar collective investment structures established primarily to invest in immovable property. Paragraph 3 of the Protocol clarifies that for Russia “unit investment funds” means funds established under Federal Law No. 156-FZ of 29 November 2001 on Investment Funds, and for the UAE a collective investment vehicle means a qualifying investment fund under UAE law.

Paragraph 7 of Article 10 carries its own anti-abuse rule: the Article does not apply if it was the main purpose or one of the main purposes of any person concerned with the creation or assignment of the shares or other rights in respect of which the dividends are paid to take advantage of the Article by means of that creation or assignment. It operates independently of the general test in Article 27 and targets the share transaction itself rather than the structure as a whole.

Interest: 10% and Three Rules That Can Erode the Relief

Paragraph 1 of Article 11 caps the source State’s tax at ten per cent of the gross amount of the interest where the beneficial owner is a resident of the other State.

The definition in paragraph 3 covers 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 them, as well as other income subjected to the same taxation treatment as income from money lent under the law of the State in which the income arises. Income dealt with in Article 10 and penalty charges for late payment are expressly excluded.

Penalties and late-payment charges are not interest for treaty purposes and therefore do not benefit from the ten per cent ceiling. Under Russian law such amounts paid to a foreign company, where they fall under subparagraph 10 of paragraph 1 of Article 309 of the Russian Tax Code as “other similar income”, are taxed at 25%. Only Article 7 can remove that charge, and only where there is no permanent establishment: falling under Article 21 does not reduce the rate, because Article 21 imposes no ceiling of its own.

Three rules can limit the relief. The first is paragraph 6 of Article 11: where, by reason of a special relationship between the payer and the beneficial owner, the amount of interest exceeds an arm’s length amount, the Article applies only to the arm’s length portion and the excess is taxed under domestic law. The second is the Russian thin capitalisation regime in Article 269 of the Russian Tax Code, and its architecture is worth holding in mind paragraph by paragraph. Paragraph 2 defines controlled debt. Paragraph 3 sets the trigger: where that debt exceeds equity — the difference between total assets and total liabilities at the last day of the reporting or tax period — by more than three times, or by more than 12.5 times for banks and leasing companies, the rules in paragraphs 4 to 6 engage. Paragraphs 4 and 5 compute the deductible interest cap. Paragraph 6 reclassifies the positive difference between accrued and capped interest as dividends paid to the foreign person and taxes it under the second paragraph of Article 224(3) or under Article 284(3). Paragraph 5 of the Protocol expressly removes Article 269 from the reach of Article 24 on non-discrimination, so the Russian rules apply to Emirati lenders in full. The third is paragraph 7 of Article 11: the Article does not apply where it was the main purpose or one of the main purposes of any person concerned with the creation or assignment of the debt claim to take advantage of the Article.

The exemption in paragraph 2 of Article 11 mirrors Article 10: zero per cent only for payments to the other Contracting State or its financial and investment institutions listed in the Protocol.

Royalties: 10% and a Definition Wider Than Most

Paragraph 1 of Article 12 caps the source State’s tax at ten per cent of the gross amount of the royalties.

The definition in paragraph 3 is worth reading in full: royalties 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 computer software, cinematograph films, or films or tapes or discs used for radio or television broadcasting, any patent, trade mark, design or model, plan, or 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.

Two elements in that definition cause most of the errors.

Computer software is named expressly. Licence fees for software paid from Russia to an Emirati rights holder fall under Article 12 and are capped at 10%; they are not exempt business profits under Article 7.

The leasing of industrial, commercial or scientific equipment is also expressly included. The OECD Model removed that limb from its royalties article back in 1992, and it is rare in modern treaties. It is present here. The consequence is that payments to an Emirati lessor for equipment are taxed in Russia at source at 10% rather than exempted under Article 7. The boundary with Article 8 is drawn not by the type of asset but by who lets it. Paragraph 3 of Article 8 treats as profits from the operation of ships or aircraft the income from renting them out on a charter basis fully equipped, crewed and supplied, and the income from bareboat rental; paragraph 4 adds income from the use, maintenance or rental of containers, including trailers, barges and related equipment for the transport of containers. In every one of those cases the same condition applies, in the treaty’s own words: “provided that such use, maintenance or rental is incidental to the operation of ships or aircraft in international traffic”. Containers carry a further carve-out: paragraph 4 does not apply to the extent the containers are used for transport solely between places within the other Contracting State. A leasing company that operates no ships or aircraft itself falls outside Article 8: its income is analysed under Article 12 as consideration for the use of industrial, commercial or scientific equipment, and is capped at 10%. The domestic rate for this category is 10% under subparagraph 2 of paragraph 2 of Article 284 of the Russian Tax Code.

The remaining paragraphs of Article 12 follow the structure of Article 11: exemption for Contracting States and their financial and investment institutions (paragraph 2), a permanent establishment carve-out (paragraph 4), a source rule (paragraph 5), an arm’s length rule (paragraph 6) and a dedicated anti-abuse rule (paragraph 7).

Table 1. Russian Withholding Tax on Payments to the UAE: Before and from 1 January 2026

Capital Gains: When the Sale of a Shareholding Is Taxable in Russia

Paragraph 5 of Article 13 states the general rule: gains from the alienation of any property other than that referred to in paragraphs 1 to 4 are taxable only in the Contracting State of which the alienator is a resident.

In practice this means that a sale by a UAE resident of an interest in a Russian limited liability company or of shares in a Russian joint-stock company is taxable only in the UAE, where corporate tax at 9% applies above the AED 375,000 threshold unless the participation exemption is available. No Russian withholding tax is due.

There is an exception, and it is drafted in detail. Paragraph 4 of Article 13 allows the State where the immovable property is situated to tax gains from the alienation of shares of a company or comparable interests — such as interests in a partnership, trust or collective investment vehicle — if at any time during the 365 days preceding the alienation at least 50% of the value of those shares or comparable interests was derived directly or indirectly from immovable property situated in that State.

The property-rich threshold under the treaty is 50% of value measured at any time within the 365 days before the alienation, not only on the date of the sale. A one-day balance-sheet adjustment before closing does not work.

The exception has its own exception: paragraph 4 does not apply where those shares or comparable interests are traded on a recognised stock exchange and the resident holds in aggregate 5% or less of that class of shares or comparable interests. A recognised stock exchange is defined in subparagraph (m) of paragraph 1 of Article 3 as any stock exchange established and regulated by the law of either Contracting State, or any other stock exchange agreed by the competent authorities.

Comparison with the domestic rule reveals a meaningful divergence. Subparagraph 5 of paragraph 1 of Article 309 of the Russian Tax Code taxes gains from the sale of shares or interests in organisations more than 50% of whose assets consist directly or indirectly of immovable property in Russia. The domestic rule speaks of assets and sets no look-back period; the treaty speaks of the value of the shares and introduces 365 days. Where the two diverge, the treaty prevails under paragraph 1 of Article 7 of the Russian Tax Code — but the taxpayer must be able to evidence the treaty test with a calculation, and that calculation is best prepared before the transaction rather than after a tax office enquiry.

The remaining paragraphs are conventional: paragraph 1 covers immovable property by situs; paragraph 2 covers movable property of a permanent establishment; paragraph 3 covers ships and aircraft in international traffic, taxable only in the State of the enterprise. Where a restructuring involves moving the company itself to the UAE rather than selling the shares, the migration mechanism requires separate analysis and is set out in Redomiciliation to the UAE in 2026.

Corporate Residence: Why Dual Residence Has Become More Dangerous

Paragraph 1 of Article 4 defines a resident of each State by reference to that State’s own tax law, but the two subparagraphs are drafted very differently.

For the UAE, a resident is any person who is a resident of the United Arab Emirates in accordance with the taxation laws of the United Arab Emirates by reason of that person’s domicile, residence, place of incorporation, place of management or any other criterion of a similar nature. The critical detail: the UAE limb contains no “liable to tax” condition. A free zone company earning qualifying income at a zero effective rate remains a UAE resident within the meaning of Article 4; actual payment of tax is not a condition.

For Russia, a resident is any person who under Russian law is liable to tax therein by reason of domicile, residence, place of management, location of its head or main office, place of registration or incorporation or any other criterion of a similar nature, and includes the Russian Federation, its political subdivisions and local authorities. The term excludes any person liable to tax in Russia solely in respect of income from sources in Russia.

The toughest provision in the Article is paragraph 3. Where a company or other non-individual is resident in both States, the competent authorities shall endeavour to determine residence by mutual agreement, having regard to the location of the head or main office, the place of effective management, the place of incorporation or constitution and any other relevant factors. The text then continues: in the absence of such agreement, the person shall not be entitled to any relief or exemption from tax provided by the Agreement except to the extent and in such manner as may be agreed upon by the competent authorities of the Contracting States.

There is no automatic corporate tie-breaker based on place of effective management. Until the competent authorities agree, there is no relief at all — none whatsoever.

This interacts with the Russian corporate residence rule. Subparagraph 3 of paragraph 1 of Article 246.2 of the Russian Tax Code treats a foreign organisation whose place of management is Russia as a Russian tax resident. Paragraph 2 of the same Article sets out the tests: either the executive body regularly carries out its activities in respect of the organisation from Russia, or the senior officers predominantly carry out executive management of the organisation in Russia. Paragraph 3 lists what does not by itself amount to management, including preparing and taking decisions within the competence of the general meeting of shareholders, preparing for meetings of the board of directors, and a number of other acts.

The realistic scenario looks like this. The owner lives in Moscow; the Emirati company is registered in a free zone; the director is a nominal UAE resident — but all operational decisions are taken from Moscow. The Russian tax authority can treat the company as a Russian tax resident under Article 246.2. The Emirati side treats it as its own resident by place of incorporation. Dual residence arises — and until the two ministries of finance agree, the company gets nothing under the Agreement. Which evidence of management in the UAE actually stands up is discussed in Relocating a Business to the UAE from Another Jurisdiction.

Individual Residence: The Treaty Tie-Breaker and the Three UAE Tests

For individuals, Article 4 provides a classic four-step tie-breaker that is applied strictly in order and stops at the first criterion that gives a clear answer.

The sequence runs: permanent home available to the individual; where a home is available in both States, the centre of vital interests (closer personal and economic relations); where the centre of vital interests cannot be determined or no permanent home is available in either State, habitual abode; where the individual has a habitual abode in both or in neither, nationality; and where the individual is a national of both or of neither, the question is settled by the competent authorities by mutual agreement.

Russia determines residence under paragraph 2 of Article 207 of the Russian Tax Code: individuals actually present in Russia for at least 183 calendar days within any 12 consecutive months are tax residents.

The UAE determines residence under Article 4 of Cabinet Decision No. 85 of 2022, effective 1 March 2023. An individual is a UAE tax resident if any one of three conditions is met: the usual or primary place of residence and the centre of financial and personal interests are in the UAE; the individual is physically present in the UAE for 183 days or more within the relevant 12 consecutive months; or the individual is physically present for 90 days or more within the relevant 12 consecutive months while holding UAE nationality, a valid residence permit or GCC nationality, and either has a permanent place of residence in the UAE or carries on employment or business in the UAE.

The 90-day test is a UAE feature with no Russian equivalent. It allows an individual to obtain UAE tax residence without severing ties elsewhere — which is precisely why it so often produces dual residence. The three tests are examined in detail in UAE Personal Tax Residency 2026.

Table 2. Tax Residence Criteria: Russia and the UAE

Permanent Establishment: 12 Months for Construction, Only 6 for Services

A permanent establishment under Article 5 is a fixed place of business through which the business of an enterprise is wholly or partly carried on. Its existence moves profit out of Article 7 and into taxation in the State where the activity occurs.

Paragraph 2 lists the typical cases: a place of management, a branch, an office, a factory, a workshop, and a mine, oil or gas well, quarry or any other place of exploration, extraction or exploitation of natural resources, including an offshore drilling rig.

Paragraph 3 adds two time thresholds, and they are not the same.

A building site, a construction, assembly or installation project or supervisory activities connected with them constitute a permanent establishment only if they last more than 12 months.

The furnishing of services, including consultancy services, through employees or other personnel engaged for that purpose constitutes a permanent establishment if activities of that nature continue, for the same or a connected project, for a period or periods aggregating more than 6 months within any 12-month period.

The gap between the two thresholds is a factor of two, and the shorter one applies to exactly what most Emirati companies with Russian clients do: supply services. The words “a period or periods aggregating more than 6 months within any 12-month period” mean the periods are added together rather than counted consecutively. Three assignments of 2.5 months each within a year total 7.5 months and breach the threshold.

Paragraph 4 lists the preparatory and auxiliary carve-outs: storage, display and delivery of goods; maintenance of stock for processing by another enterprise; purchasing goods; collecting information; any other activity of a preparatory or auxiliary character; and any combination of those activities, provided the combination retains that character.

Paragraph 5 is the anti-fragmentation rule. The carve-outs in paragraph 4 do not apply where the same enterprise or a closely related enterprise carries on business at the same place or at another place and either that place constitutes a permanent establishment or the overall activity is not of a preparatory or auxiliary character, provided the business activities carried on by the two enterprises constitute complementary functions that are part of a cohesive business operation.

Paragraphs 6 and 8 address agency, and paragraph 7 adds a separate rule for insurance: an enterprise of a Contracting State that carries on insurance business, other than reinsurance, has a permanent establishment in the other State if it collects premiums or insures risks there through a person who is not an independent agent. A dependent agent is a person who habitually concludes contracts, or habitually plays the principal role leading to the conclusion of contracts that are routinely concluded by the enterprise without material modification, where those contracts are in the name of the enterprise, or for the transfer of ownership of or the granting of the right to use property of the enterprise, or for the provision of services by the enterprise. A person acting exclusively or almost exclusively on behalf of one or more closely related enterprises is not an independent agent.

Paragraph 9 confirms that control of one company over another does not of itself create a permanent establishment. Paragraph 10 defines “closely related” by reference to control or to direct or indirect participation of more than 50% — for a company, more than 50% of the aggregate vote and value of the shares or more than 50% of the beneficial equity interest.

For comparison, subparagraph (i) of paragraph 2 of Article 14 of Federal Decree-Law No. 47 of 2022 sets a 6-month threshold for building sites under UAE domestic law. The Agreement raises it to 12 months, and between the two States the treaty threshold governs.

Article 21, Other Income: An Unusual Rule Favouring the Source State

Article 21 of the Agreement allocates income not dealt with elsewhere in the treaty to the source State rather than the residence State. That is the reverse of the OECD Model.

The full text reads: “Items of income of a resident of a Contracting State, which arise in the other Contracting State, not dealt with in the foregoing Articles of this Agreement may be taxed in that other Contracting State.”

Article 21 of the OECD Model does the opposite: other income is taxable only in the State of residence. Here the taxing right goes to the source, and Article 21 imposes no rate ceiling at all.

One detail deserves attention, because it turns on the relationship between the Russian and English texts. The Russian version reads «подлежат налогообложению», which reads as an exclusive allocation to the source State. The English version reads “may be taxed” — a non-exclusive allocation under which the residence State keeps its own taxing right and double taxation is relieved by the credit in Article 23. The English text prevails in the event of divergence in interpretation, so the correct reading is this: the source State may tax other income with no rate ceiling, and the residence State must give a credit.

The practical effect: an item of income that cannot be brought within Articles 6 to 20 loses its treaty rate ceiling and is taxed in Russia under domestic rules — under subparagraph 10 of paragraph 1 of Article 309 and subparagraph 1 of paragraph 2 of Article 284 of the Russian Tax Code that means 25%.The qualification matters: subparagraph 10 does not catch every payment but only “other similar income”, that is, income of the same passive character as the items listed in subparagraphs 1 to 9.5, so landing in Article 21 does not by itself create a Russian charge — it merely removes the treaty’s protection.

This dictates a working rule for payments: before applying a reduced rate, identify which Article of the Agreement covers the specific payment. If a payment is not dividends (Article 10), interest (Article 11), royalties (Article 12), a capital gain (Article 13), business profits in the absence of a permanent establishment (Article 7) or income from immovable property (Article 6), it falls into Article 21 and carries no treaty rate ceiling. Contractual penalties, certain compensation payments and some exit payments all require separate analysis. Groups that split functions across several jurisdictions should compare treaty networks before fixing a structure; the comparison is set out in Hong Kong + UAE: Dual Structure for International Business 2026.

Capital and Hydrocarbons: Two Articles That Usually Get Missed

Article 22 allocates the right to tax capital, and Article 30 carves hydrocarbon income out of the Agreement altogether. Neither features in the popular commentary, and both change the answer.

Article 22 follows the logic of Article 13. Capital represented by immovable property within Article 6 may be taxed in the State where the property is situated. Capital represented by movable property forming part of the business property of a permanent establishment may be taxed in the State of that establishment. Capital represented by ships and aircraft operated in international traffic, and by movable property connected with their operation, is taxable only in the State of the enterprise. Paragraph 4 closes the structure: all other elements of capital of a resident of a Contracting State are taxable only in that State.

The practical conclusion from Article 22: shares and interests in Russian companies owned by a UAE resident are outside Russian property tax, while Russian immovable property is within it regardless of who owns it. That is precisely why the tax on property of enterprises and the tax on property of individuals appear in the list of covered taxes in Article 2.

Article 30 is drafted more forcefully than any other provision of the treaty: notwithstanding any other provisions of the Agreement, nothing shall affect the right of either Contracting State, any local government or its political subdivision or local authority, to apply its domestic laws and regulations relating to the taxation of income and profits derived from hydrocarbons and associated activities carried on in the territory of the Contracting State concerned, as the case may be.

Income and profits from hydrocarbons and associated activities are carved out of the Agreement in their entirety: the 10% ceilings, the permanent establishment rules and the allocation articles do not apply to them. For oilfield services businesses this means the treaty arithmetic is simply unavailable, and the answer comes from the domestic law of the State concerned, including Emirate-level taxation of extractive activity in the UAE.

Remote Work and Remote Services: the Protocol Provision That Closes a Popular Scheme

Paragraph 4 of the Protocol treats remote employment and remotely supplied personal services as exercised in the State of which the employer or client is a resident.

The Protocol provides that, for the purposes of paragraph 1 of Article 14, the concept of employment exercised in a Contracting State includes employment exercised remotely under an employment contract with an employer or a person who is a resident of that Contracting State, and the supply of services by an individual remotely under a contract with a company or person who is a resident of that Contracting State — irrespective of the physical presence in that State of the employee or the individual supplying those services at the time the activity is carried out or the services are supplied.

Relocating to Dubai does not by itself take remuneration from a Russian employer outside Russian tax: under paragraph 4 of the Protocol the employment is treated as exercised in Russia regardless of where the employee physically is.

This is fully aligned with Russian domestic law. Subparagraph 6.2 of paragraph 1 of Article 208 of the Russian Tax Code treats as Russian-source income remuneration for the performance of a remote employee’s function remotely under a contract with an employer that is a Russian organisation, or with a Russian-registered separate subdivision of a foreign organisation. Subparagraph 6.3 extends the same treatment to remuneration for works and services performed, and for grants of rights to use intellectual property, over the internet through domain names and network addresses in the Russian national domain zone, or through information systems or hardware-and-software complexes located in Russia, provided at least one of three conditions is met: the individual is a Russian tax resident; the income is received into an account with a bank located in Russia; or the payer is a Russian organisation, individual entrepreneur, notary, advocate or Russian-registered separate subdivision of a foreign organisation.

The rate for such income is set by paragraph 3.1 of Article 224 of the Russian Tax Code, as amended by Federal Law No. 425-FZ of 28 November 2025, and applies irrespective of residence. The ladder has five rungs: 13% where the relevant income for the tax period is RUB 2.4 million or less; RUB 312,000 plus 15% of the excess over RUB 2.4 million where income exceeds RUB 2.4 million but does not exceed RUB 5 million; RUB 702,000 plus 18% of the excess over RUB 5 million where income exceeds RUB 5 million but does not exceed RUB 20 million; RUB 3,402,000 plus 20% of the excess over RUB 20 million where income exceeds RUB 20 million but does not exceed RUB 50 million; and RUB 9,402,000 plus 22% of the excess over RUB 50 million where income exceeds RUB 50 million. The same law added a carve-out: paragraph 3.1 does not apply to an individual who held foreign-agent status on any day of the tax period, for whom the general 30% rate applies instead.

For a remote employee of a Russian employer the 13% or 15% rate applies whether or not the employee is a Russian tax resident. Changing residence does not push the individual to 30%, but neither does it remove the Russian tax.

A different picture emerges where an Emirati company supplies services to a Russian client. There Article 14 does not apply; Article 7 does, and business profits are taxable only in the UAE unless the business is carried on through a permanent establishment in Russia. This matters because, since 2024, subparagraph 9.4 of paragraph 1 of Article 309 of the Russian Tax Code has treated as Russian-source income the income of a foreign organisation from works performed or services supplied in Russia to a related party, with works treated as performed in Russia where the purchaser carries on activity in Russia. Before 2026 such payments were taxed at source at 20% in 2024 and at 25% from 1 January 2025, after Federal Law No. 176-FZ of 12 July 2024 amended subparagraph 1 of paragraph 2 of Article 284 of the Russian Tax Code. From 1 January 2026 Article 7 of the Agreement removes that tax — provided there is no permanent establishment, the supporting documents are in place and the Article 27 test is satisfied. ## Entitlement to Benefits: The Article 27 PPT and Three Separate Rules in Articles 10, 11 and 12

Article 27, Entitlement to Benefits, is a principal purposes test that permits either State to deny any treaty benefit where obtaining that benefit was one of the principal purposes of an arrangement or transaction.

The text provides that, notwithstanding the other provisions of the Agreement, a benefit shall not be granted in respect of an item of income if it is reasonable to conclude, having regard to all relevant facts and circumstances, that obtaining that benefit was one of the principal purposes of any arrangement or transaction that resulted directly or indirectly in that benefit, unless it is established that granting that benefit in these circumstances would be in accordance with the object and purpose of the relevant provisions of the Agreement.

Three features of that test deserve emphasis. First, the evidential threshold is low: it is enough that the conclusion be reasonable; it need not be proved. Second, the tax benefit need only be one of the principal purposes, not the sole or dominant one. Third, the burden of rebuttal effectively sits with the taxpayer, because the saving proviso operates only where consistency with the object and purpose is established.

Alongside the general test, the Agreement contains three dedicated anti-abuse rules: paragraph 7 of Article 10, paragraph 7 of Article 11 and paragraph 7 of Article 12. All three are drafted identically and deny the benefits of the relevant Article where it was the main purpose or one of the main purposes of a person concerned with the creation or assignment of shares, a debt claim or rights to take advantage of that Article by means of the creation or assignment. They apply to the specific transaction and operate in parallel with Article 27.

Russian law adds its own beneficial ownership concept. Paragraph 3 of Article 7 of the Russian Tax Code provides that a foreign person is not treated as the beneficial owner of income where it has limited powers to dispose of that income, performs intermediary functions in the interests of another person without performing any other functions or assuming any risks, and pays that income directly or indirectly to that other person, who would not have been entitled to the treaty benefit had it received the income from Russia directly.

Three layers of control operate simultaneously and independently: the beneficial ownership test in Article 7 of the Russian Tax Code, the Article-specific rules in paragraph 7 of Articles 10, 11 and 12, and the general test in Article 27 of the Agreement. Passing one does not substitute for passing the others.

In practice an inspector looks at a factual bundle: whether the Emirati company has an office and staff in the UAE, whether decisions are taken there, whether the company bears commercial risk, whether income stays in the company or passes straight through, whether the structure was created shortly before the payment, and whether it has a business purpose beyond tax. UAE substance requirements, including the conditions for Qualifying Free Zone Person status, are set out in How to Set Up a Company in the UAE in 2026.

One Emirati requirement arrived in 2026 and barely features in the commentary. Federal Tax Authority Decision No. 6 of 2026, “Determining the Additional Procedures for the Compliance of Qualifying Free Zone Persons Engaged in the Activity of Distribution of Goods or Materials in or from a Designated Zone”, was issued on 2 June 2026, published on 14 July 2026 and applies to tax periods starting on or after 1 January 2026. A free zone company whose qualifying activity is distribution must obtain an agreed-upon procedures report, prepared under International Standard on Related Services 4400 by the independent external auditor who audits its financial statements or by another auditor licensed in the UAE. The report must establish two things: that the company’s customers qualify as resellers, and that goods entering the UAE, where imported by the company, came in through a Designated Zone.

The report must reach the Authority no later than thirty days after the deadline for filing the Corporate Tax return for the period; if it does not, the conditions for treating distribution as a qualifying activity are not considered met. For a structure built on the QFZP zero rate that is a route to losing the status — and with it, under paragraph 2 of Article 5 of Ministerial Decision No. 229 of 2025, the current tax period and the four that follow.

Relief from Double Taxation: Credit Only, No Exemption

Article 23 provides a single relief method — a credit for tax paid in the other State. Neither side has an exemption method.

On the Russian side, paragraph 2 works as follows: where a resident of the Russian Federation derives income or owns capital that, in accordance with the Agreement, may be taxed in the UAE, the amount of tax on that income or capital payable in the UAE shall be deducted from the Russian tax levied on that resident. The deduction may not exceed the amount of Russian tax on that income or capital computed in accordance with Russian tax law.

On the UAE side, paragraph 1 mirrors this: a deduction from UAE tax on income equal to the income tax paid in Russia, and a deduction from UAE tax on capital equal to the capital tax paid in Russia, subject to the same cap.

For individuals this is a material change. Paragraph 1 of Article 232 of the Russian Tax Code provides that amounts of tax actually paid by a Russian tax resident individual outside Russia on foreign income are not credited against Russian tax unless the relevant tax treaty provides otherwise. Before 1 January 2026 there was no treaty with the UAE providing for a credit, so no credit was available. From 1 January 2026 Article 23 opens the door, and the credit is granted by the tax authority under the procedure in paragraphs 2 to 4 of Article 232.

The practical value of that credit for individuals is limited by one simple fact: the UAE levies no personal income tax. There is usually nothing to credit. The credit becomes real for an individual carrying on business in the UAE and paying corporate tax as a natural person, and for Russian companies that have paid UAE corporate tax through a permanent establishment or otherwise.

What Changed in Russian Law: the UAE Leaves Both Offshore Lists

From 1 January 2026 the UAE is out of both Russian Ministry of Finance offshore lists — the main list and the special list. This is a separate change, not contained in the Agreement, but synchronised with the date the Agreement takes effect.

The List of Offshore Zones approved by Order No. 86n of 5 June 2023 carried the UAE at item 38, between “New Zealand” and “the Cayman Islands”. Order No. 187n of 22 December 2025 repealed that item, citing the second paragraph of subparagraph 1 of paragraph 3 of Article 284 of the Russian Tax Code.

The Special List of Offshore Zones approved by Order No. 35n of 28 March 2024 carried the UAE at item 20, between the entry for certain administrative units of the United Kingdom and “Anjouan Island of the Union of the Comoros”. The Special List contains 40 entries and applies to tax periods 2024 to 2026 for corporate profits tax and personal income tax. Order No. 188n of 22 December 2025 repealed item 20.

The main practical consequence concerns the reverse direction of the cash flow — and here the two lists must not be confused. The second paragraph of subparagraph 1 of paragraph 3 of Article 284 of the Russian Tax Code provides that the 0% rate on dividends received by a Russian organisation applies, where the payer is a foreign company, only if the State of the payer’s permanent location is not included in the Ministry of Finance offshore list.

For tax periods 2024 to 2026, it is the Special List and not the main list that governs subparagraph 1 of paragraph 3 of Article 284 of the Russian Tax Code. That is the effect of Article 4 of Federal Law No. 595-FZ of 19 December 2023, under which the Ministry of Finance approves, for 2024 to 2026, a special list for the purposes of the CFC exemption in the third paragraph of paragraph 7 of Article 25.13-1, the CFC profit adjustment in subparagraph 3 of paragraph 1.2 of Article 25.15, the tax base determination in the third paragraph of subparagraph 11 of paragraph 1 of Article 251, and the application of the rates in subparagraph 1 or 1.1 of paragraph 3 of Article 284. The zero rate on dividends from the UAE in 2026 is therefore opened by Order No. 188n, which removed the UAE from the Special List, and not by Order No. 187n. Order No. 187n operates on the other Tax Code provisions that refer to the main list. Article 4 of Federal Law No. 595-FZ confines the Special List to tax periods 2024 to 2026, so from tax period 2027 the same provisions revert to the main list and Order No. 187n becomes the decisive one. For the UAE the outcome is identical either way — it is out of both lists — but the supporting citation in a 2026 return differs from the one in a 2027 return.

From 1 January 2026 a Russian company holding at least a 50% interest in an Emirati company continuously for at least 365 calendar days may apply a 0% rate to dividends received from it. Before that date the same distribution was taxed in Russia at 13% under subparagraph 2 of paragraph 3 of Article 284 of the Russian Tax Code.

Table 3. What Changes for a Company Owner from 1 January 2026

Controlled Foreign Companies: What Changed and What Did Not

The Agreement does not displace the Russian controlled foreign company rules. Paragraph 5 of the Protocol expressly removes Chapter 3.4 of Part One of the Russian Tax Code, and Articles 269 and 309.1 of Part Two, from the reach of Article 24 on non-discrimination.

The Protocol states that nothing in Article 24 shall be construed as restricting the application of, in the case of the UAE, the Corporate Tax Law as amended in a way that does not change its general principle, and, in the case of Russia, Chapter 3.4 of Part One of the Tax Code (Law No. 146-FZ of 31 July 1998) and Articles 269 and 309.1 of Chapter 25 of Part Two (Law No. 117-FZ of 5 August 2000), as amended in a way that does not change their general principle.

An Emirati company controlled by a Russian tax resident remains a controlled foreign company. The obligations to file participation notices and CFC notices continue. CFC profit is included in the controlling person’s tax base where that profit, computed under Article 309.1, exceeds RUB 10,000,000 (paragraph 7 of Article 25.15).

What has changed is this. Paragraph 7 of Article 25.13-1 makes the exemptions in subparagraphs 3, 5 and 6 of paragraph 1 conditional on the CFC’s State of permanent location having a tax treaty with Russia, provided that State is not on the list of States that do not exchange tax information. Before 2026 there was no full treaty with the UAE: the 2011 agreement covered only income from investments of the Contracting States themselves and their financial and investment institutions. From 1 January 2026 the treaty condition is satisfied. The UAE does not appear on the list of non-exchanging States approved by Federal Tax Service Order No. ED-7-17/914@ of 30 October 2024.

What has not changed matters more. The exemption in subparagraph 3 of paragraph 1 of Article 25.13-1 requires the CFC’s effective rate of tax to be at least 75% of the weighted average Russian corporate profits tax rate. In the formula in paragraph 2 of that Article, Rate 1 is the rate in the first paragraph of paragraph 1 of Article 284 (25%) and Rate 2 is the rate in subparagraph 2 of paragraph 3 of Article 284 (13%). The weighted average therefore lies between 13% and 25%, and 75% of it lies between 9.75% and 18.75%.

The UAE corporate tax rate of 9% is below the effective-rate threshold under every possible computation, and for a Qualifying Free Zone Person the effective rate on qualifying income is nil. The subparagraph 3 exemption is unavailable for an Emirati CFC.

A further restriction arrived very recently. The third paragraph of paragraph 7 of Article 25.13-1, as amended by Federal Law No. 425-FZ of 28 November 2025, applies to CFC profit for tax periods from 2026 and requires two conditions to be met simultaneously for an active foreign holding or sub-holding company: the State of its permanent location must not be on the Russian Ministry of Finance offshore list — for tax periods 2024 to 2026 that means the same Special List, under Article 4 of Federal Law No. 595-FZ of 19 December 2023 — and the law of that State must impose a corporate profits tax rate of not less than 15%.

Removing the UAE from the offshore list satisfies the first condition, but the second is not met at the Emirati 9% rate. The active foreign holding company exemption is therefore unavailable for a UAE holding company from 2026. It is sometimes suggested that the UAE Domestic Minimum Top-up Tax, with its 15% effective rate, saves the position. The Russian provision is drafted differently: it requires the law of the State to impose a corporate profits tax rate of not less than 15%, whereas the rate imposed by UAE law remains 9% under paragraph 1 of Article 3 of Federal Decree-Law No. 47 of 2022, and the top-up tax is a separate charge reaching only multinational groups with annual global revenues of EUR 750 million or more. Until an official position emerges, the exception should not be relied on.

The information environment deserves separate attention. The UAE appears at item 46 of the List of States with which Automatic Exchange of Financial Information Is Carried Out, approved by Federal Tax Service Order No. ED-7-17/883@ of 14 October 2025. Data on Emirati accounts reaches the Russian Federal Tax Service automatically, without a request. Article 26 of the Agreement adds exchange on request, and paragraph 5 of that Article expressly denies a State the right to decline to supply information solely because the information is held by a bank, other financial institution, nominee, agent or fiduciary.

The Certificate of Residence and Beneficial Ownership: Claiming Relief in Practice

The reduced rate is applied by the withholding agent itself, but only if two documents are in hand before the income is paid.

Paragraph 1 of Article 312 of the Russian Tax Code requires the foreign organisation that is the beneficial owner of the income to provide the withholding agent with, first, confirmation of its permanent location in a State with which Russia has a tax treaty, certified by the competent authority of that State, and, second, confirmation that it is the beneficial owner of the relevant income. Where the confirmation is drawn up in a foreign language, a Russian translation must also be provided.

The provision is explicit about timing: providing the confirmations to the withholding agent before the date the income is paid is the basis for exemption from withholding or for withholding at reduced rates. A document obtained after payment does not entitle the agent to apply the reduced rate at the moment of payment. A certificate issued later that confirms residence for the relevant period is generally accepted as a basis for recovering the over-withheld tax through the tax authority under paragraph 2 of Article 312 of the Russian Tax Code. The refund itself is made by the tax office where the withholding agent is registered, in roubles, on an application with supporting documents, “in a manner analogous to that established by Article 79 of this Code for amounts of tax claimed for refund”; since the single tax account reform, Article 78 governs set-off rather than refund, and citing it here is wrong. Late-payment interest for the intervening period and the question of the agent’s conduct both remain live.

On the UAE side the required document is a Tax Residency Certificate issued by the Federal Tax Authority specifically for the purposes of an international agreement. The procedure is governed by Ministerial Decision No. 247 of 2023, dated 16 October 2023: an application is made by a person meeting the conditions of tax residency in the State under the relevant international agreement, and the certificate is issued where the Authority is satisfied those conditions are met. This is a distinct document type: the “domestic” TRC confirming residence for UAE law purposes does not satisfy Article 312 of the Russian Tax Code. The application process, timelines and the usual grounds for refusal are covered in UAE Tax Residency Certificate (TRC). Applications are made from the EmaraTax portal through the Authority’s dedicated Tax Residency Certificate platform at trc.tax.gov.ae, open around the clock. The fees are set by Cabinet Decision No. 65 of 2020 on the fees for services provided by the Federal Tax Authority, as amended, and are not refunded even if the application is rejected: a submission fee of AED 50; review and issuance of an electronic certificate to a person registered for Corporate Tax, AED 500; to a natural person without a Corporate Tax TRN, AED 1,000; to a juridical person without one, AED 1,750; and AED 250 for each hard copy. The stated turnaround is ten business days from receipt of a complete application, plus five business days for a hard copy once the fee is paid.

For a juridical person, the documents required for a certificate issued for treaty purposes include “proof of effective management and control in the UAE”. That dovetails exactly with paragraph 3 of Article 4 of the Agreement and with Article 246.2 of the Russian Tax Code: the very fact a Russian inspector tests in order to treat the company as a Russian resident is the fact the Emirati regulator tests in order to issue the certificate. One further detail from the Authority’s service card: a Corporate Tax Group is not an entity that is incorporated, established or otherwise recognised and therefore cannot be a UAE tax resident, so each member applies separately and the reduced fee does not apply on the group’s credentials.

In practice assembling the supporting file takes longer than the review itself, so licence-renewal and corporate-document-renewal dates are worth aligning with the payment calendar; the renewal mechanics are set out in UAE Company / Trade Licence Renewal 2026.

One significant simplification comes from paragraph 6 of the Protocol: any document received under Article 26 of the Agreement, or a certificate of residence issued by the competent authority of a Contracting State, shall not require legalisation or apostille for the purposes of application in the other Contracting State, including use before administrative bodies.

No apostille is required on a UAE certificate of residence for treaty purposes — this is stated expressly in paragraph 6 of the Protocol, which forms an integral part of the Agreement. A Russian translation nevertheless remains mandatory under paragraph 1 of Article 312 of the Russian Tax Code.

Confirmation of beneficial ownership is not formalised in statute. In practice it is a letter from the recipient representing that it disposes of the income independently and is under no obligation to pass it on, and setting out the functions it performs and the risks it bears, supported by financial statements, evidence of staff and premises, board minutes and contracts that explain the commercial purpose.

A Step-by-Step Procedure for Company Owners

The procedure below assumes a structure in which a Russian company or individual pays income to an Emirati company, or receives income from the UAE. It is designed to be completed before the first payment of 2026, not after it.

Step 1. Establish the tax residence of every entity in the structure. For the Emirati company, verify not only registration but also the ability to obtain a TRC for treaty purposes; substance and reporting requirements differ from zone to zone, and individual zones are compared in RAKEZ, Meydan Free Zone 2026 and Ajman Free Zone 2026. For individuals, count days under both tests — the Russian 183 days under paragraph 2 of Article 207 of the Russian Tax Code and the Emirati tests in Article 4 of Cabinet Decision No. 85 of 2022.

Step 2. Assess the risk of dual corporate residence. Answer in writing where the executive body regularly acts and where senior officers predominantly exercise executive management (paragraph 2 of Article 246.2 of the Russian Tax Code). Under dual residence no treaty relief is available until the competent authorities agree (paragraph 3 of Article 4 of the Agreement).

Step 3. Classify every payment by treaty Article. Assign each cash flow to a specific Article: 6, 7, 8, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20 or 22 — and, failing all of those, 21. Payments that land in Article 21 carry no rate ceiling. Check Article 30 separately: hydrocarbon income and related activities are carved out of the Agreement entirely.

Step 4. Test the permanent establishment thresholds. Add up the days Emirati personnel spend in Russia across any 12-month period. The services threshold is more than 6 months in aggregate; the construction threshold is more than 12 months.

Step 5. Obtain a UAE TRC for treaty purposes covering the right period. Certificates are issued for a defined period; check that it covers the planned payment dates.

Step 6. Prepare the beneficial ownership confirmation. It must be dated no later than the payment date.

Step 7. Arrange Russian translations. No apostille is needed; a translation is.

Step 8. Run a self-assessment against the Article 27 test. Articulate a non-tax business purpose for the structure and support it with contracts, correspondence, board resolutions and evidence of staff and premises.

Step 9. Check the thin capitalisation rules on any intra-group loan. Compare the controlled debt with equity under paragraph 3 of Article 269 of the Russian Tax Code (the trigger is more than three times, or more than 12.5 times for banks and leasing companies), compute the deductible interest cap under paragraphs 4 and 5, and identify the amount reclassified as dividends under paragraph 6.

Step 10. Update CFC compliance. File notices on time, compute CFC profit under Article 309.1 and check whether it exceeds RUB 10,000,000.

Step 11. Set up the document flow with the withholding agent. Oblige the recipient to deliver a TRC and a beneficial ownership confirmation annually before the first payment of each period.

Step 12. Record the position in writing. Prepare an internal memorandum setting out the rate calculation with references to the governing provisions. That memorandum is the first document a tax inspector will ask for. ## Common Mistakes and What They Cost

Mistake 1. Assuming the Agreement applies to 2025. The Agreement entered into force on 18 July 2025 but applies from 1 January 2026. A payment made on 20 December 2025 is taxed at domestic rates — 15% on dividends and 25% on interest and royalties. The cost is the assessed difference, late-payment interest and a penalty of 20% of the under-withheld amount under Article 123 of the Russian Tax Code. Moving a RUB 100 million dividend a few days across the year-end changes the tax from RUB 15 million to RUB 10 million.

Mistake 2. Obtaining an ordinary UAE TRC instead of a certificate for treaty purposes. These are two different documents issued on different bases; Ministerial Decision No. 247 of 2023 governs the treaty certificate specifically. The cost is that the withholding agent applies a reduced rate on the strength of an unusable document and the tax authority then withdraws the relief in full rather than in part: the assessment is the entire spread between the domestic and the treaty rate, 15 percentage points on interest and royalties and 5 on dividends.

Mistake 3. Obtaining the supporting documents after payment. Paragraph 1 of Article 312 of the Russian Tax Code ties the reduced rate to delivery of the confirmations before the payment date. The cost is under-withholding at the moment of payment, late-payment interest running until recovery, and recovery through the tax authority under paragraph 2 of Article 312 — a process measured in months and sometimes in litigation.

Mistake 4. Believing a zero-taxed free zone company cannot be a UAE resident under the Agreement.Subparagraph (a) of paragraph 1 of Article 4 contains no “liable to tax” condition. The opposite error is equally common: assuming Qualifying Free Zone Person status automatically confers treaty benefits. It does not — a treaty TRC, a beneficial ownership confirmation and satisfaction of the Article 27 test are all still required. Either error costs money: overpaid tax in one direction, an assessment in the other.

Mistake 5. Overlooking Article 21 on other income. Owners are accustomed to other income being taxable in the residence State. Here the position is reversed: Article 21 allocates it to the source State with no rate ceiling. The cost is that a payment assumed to be protected is taxed in Russia at 25% under subparagraph 10 of paragraph 1 of Article 309 of the Russian Tax Code.

Mistake 6. Ignoring the six-month services permanent establishment threshold. The services threshold is more than 6 months in aggregate within any 12-month period — not 183 consecutive days, and not the 12 months that apply to construction. The cost is that all profit of the Emirati company attributable to the Russian activity becomes taxable in Russia at 25% — paragraph 6 of Article 307 of the Russian Tax Code refers to the rates in paragraph 1 of Article 284, while dividends and part of the interest income attributable to the permanent establishment are taxed separately under subparagraph 3 of paragraph 3 and paragraph 4 of Article 284 — together with retrospective registration and filing obligations.

Mistake 7. Assuming relocation to the UAE takes a Russian salary outside Russian tax. Paragraph 4 of the Protocol and subparagraphs 6.2 and 6.3 of paragraph 1 of Article 208 of the Russian Tax Code say the opposite. The cost falls on the employer as withholding agent: assessed personal income tax for the whole period, late-payment interest and a penalty under Article 123.

Mistake 8. Failing to test interest against the thin capitalisation rules. Paragraph 5 of the Protocol expressly removes Article 269 of the Russian Tax Code from the non-discrimination article. Excess interest is reclassified as dividends and loses deductibility for the Russian borrower. The cost is doubled: profits tax at 25% on the disallowed expense plus withholding tax on the reclassified amount.

Mistake 9. Assuming that leaving the offshore lists solved the CFC problem, and confusing which of the two lists governs. For tax periods 2024 to 2026, subparagraph 1 of paragraph 3 of Article 284 and the third paragraph of paragraph 7 of Article 25.13-1 of the Russian Tax Code refer to the Special List (Order No. 35n, repealed as to the UAE by Order No. 188n), not to the main list (Order No. 86n, repealed as to the UAE by Order No. 187n); Article 4 of Federal Law No. 595-FZ of 19 December 2023 says so expressly. The effective-rate exemption requires at least 75% of the weighted average Russian rate, and the Emirati 9% falls below it. The active foreign holding company exemption requires, from 2026, a rate of not less than 15% under the third paragraph of paragraph 7 of Article 25.13-1 as amended by Federal Law No. 425-FZ of 28 November 2025. The cost of an unfiled CFC notice is RUB 500,000 per company under paragraph 1 of Article 129.6 of the Russian Tax Code, plus tax on undistributed profit.

Mistake 10. Apostilling the certificate of residence “just in case”. Paragraph 6 of the Protocol expressly dispenses with legalisation and apostille. The monetary cost is small, but the time cost is not: consular legalisation and apostille are multi-stage procedures that can cause a payment deadline to be missed when the Protocol would have allowed it to be met.

Mistake 11. Building a structure around the 10% rate alone. The Article 27 test requires only that a conclusion be “reasonable”. A company with no staff, no premises, no independent decision-making and no commercial risk does not pass it. The cost is denial of relief in full and recharacterisation, with assessments for every period within the audit window.

Mistake 12. Forgetting VAT. The Agreement does not cover value added tax: Article 2 lists taxes on income and on capital only. The Russian purchaser’s obligations as a VAT withholding agent on services acquired from an Emirati company remain in full.

Who It Suits, Who It Does Not, and When Professional Review Is Essential

The Agreement delivers real savings to structures in which the Emirati company carries on its own business and disposes of its own income.

The regime suits holding structures genuinely managed in the UAE, where decisions are taken on the ground, the company has an office and staff, and dividends are retained or reinvested. It suits licensing and IT structures where the software rights genuinely belong to the Emirati company and development or its funding was directed from the UAE. It suits intra-group financing within the limits of the thin capitalisation rules. It suits service companies supplying Russian clients without prolonged personnel presence in Russia. It suits Russian groups with an Emirati subsidiary that plans to distribute dividends to Russia: from 2026 a 0% Russian rate applies where a holding of at least 50% has been held for at least 365 days. It suits individuals who have genuinely relocated and can evidence a centre of vital interests in the UAE. Digital asset businesses warrant separate attention: their income rarely fits Articles 10 to 12 and is more often analysed under Articles 7 and 21, and the regulatory perimeter is described in Crypto Business in the UAE in 2026.

The regime does not suit conduit companies with no functions and no risks. Paragraph 3 of Article 7 of the Russian Tax Code and the Article 27 test address such structures directly.

It does not suit structures created immediately before a large payment: paragraph 7 of each of Articles 10, 11 and 12 targets precisely the creation or assignment of shares, debt claims and rights for the sake of a benefit. It does not suit companies managed from Russia, which risk being treated as Russian tax residents under Article 246.2 of the Russian Tax Code and losing all treaty relief under paragraph 3 of Article 4. It does not suit owners hoping that the CFC rules will fall away: the Protocol preserves Chapter 3.4 of the Russian Tax Code expressly. And it does not suit anyone planning to use the UAE as an intermediate step towards third jurisdictions: the preamble names that pattern as the target of the treaty’s anti-abuse provisions.

Professional review is essential in six situations. First, dual residence of a company or an individual, because without a competent authority agreement there is no relief at all. Second, a sale of shares or interests where the immovable property share of value approaches 50% or has fluctuated during the 365 days before the transaction. Third, personnel presence in Russia approaching the six-month threshold. Fourth, intra-group loans where the controlled debt exceeds equity by more than three times under paragraph 3 of Article 269 of the Russian Tax Code, or by more than 12.5 times for banks and leasing companies. Fifth, payments that cannot be assigned confidently to Articles 6 to 20 and risk falling into Article 21. Sixth, any ownership restructuring carried out after 17 February 2025, because its chronology will be examined through the lens of the principal purposes test.

If you are still choosing a form of presence in the UAE, start by comparing jurisdictions: ADGM 2026, DIFC 2026 and Mainland, Free Zone or Offshore set out the differences in regulator, reporting and banking access. Audit requirements, which largely determine how provable your substance is, are covered in Corporate Audit Requirements in the UAE 2026.

Need a structure that survives both the Article 27 test and a place-of-management review?The UPPERSETUP team handles UAE company formation, free zone selection, TRC applications and the document flow required to claim the Agreement — discuss your case. ## Every Threshold and Time Limit in One Place

The figures below govern the application of the Agreement. Each value is taken from the treaty text, the Protocol or the domestic provision named in the row.

Table 4. Thresholds and Time Limits

Frequently Asked Questions

From what date does the Russia–UAE double tax treaty apply?

It applies from 1 January 2026. The treaty itself entered into force on 18 July 2025, but Article 31 separates the two dates: for withholding taxes the treaty applies to amounts paid or credited on or after 1 January 2026, and for other taxes on income to tax periods beginning on or after that date. Both dates are confirmed by the Russian Ministry of Finance Information Notice of 3 December 2025.

What is the withholding tax rate on dividends from Russia to the UAE from 2026?

No more than 10% of the gross amount, provided the beneficial owner is a UAE resident. There is no participation threshold: the rate is the same for a 1% holding and a 100% holding. A zero rate applies only to payments to a Contracting State itself or to its financial and investment institutions listed in paragraph 1 of the Protocol. Without the treaty the rate would be 15% under subparagraph 3 of paragraph 3 of Article 284 of the Russian Tax Code.

Is an apostille required on a UAE tax residency certificate?

No. Paragraph 6 of the Protocol provides expressly that a certificate of residence issued by the competent authority of a Contracting State does not require legalisation or apostille for the purposes of application in the other Contracting State, including use before administrative bodies. A Russian translation nevertheless remains mandatory under paragraph 1 of Article 312 of the Russian Tax Code.

Does the treaty override the Russian controlled foreign company rules?

No. Paragraph 5 of the Protocol expressly removes Chapter 3.4 of Part One of the Russian Tax Code and Articles 269 and 309.1 of Part Two from the reach of Article 24 on non-discrimination. Participation and CFC notices are still required, CFC profit is included where it exceeds RUB 10,000,000, and the effective-rate exemption is unavailable because the Emirati 9% falls below 75% of the weighted average Russian rate.

Is salary from a Russian employer still taxed in Russia after relocating to Dubai?

Yes. Paragraph 4 of the Protocol treats remote employment under a contract with an employer resident in a Contracting State as employment exercised in that State, irrespective of the employee’s physical presence. Russian law says the same in subparagraph 6.2 of paragraph 1 of Article 208 of the Russian Tax Code, and the rate in paragraph 3.1 of Article 224 applies irrespective of residence, running from 13% on income up to RUB 2.4 million per tax period to RUB 9,402,000 plus 22% of the excess over RUB 50 million.

Can a UAE resident sell an interest in a Russian company without Russian tax?

Yes, provided the company is not property-rich. Under paragraph 5 of Article 13, gains from the alienation of property not covered by paragraphs 1 to 4 are taxable only in the alienator’s State of residence. The exception is paragraph 4 of Article 13: where at least 50% of the value of the shares or comparable interests was derived directly or indirectly from Russian immovable property at any time during the 365 days before the alienation, Russia may tax the gain. That exception does not apply to listed securities where the holding is 5% or less of the class.

Does Qualifying Free Zone Person status affect the availability of treaty relief?

No, and the converse is equally untrue. Qualifying Free Zone Person status concerns UAE corporate tax and delivers a 0% rate on qualifying income. It neither confers nor removes treaty entitlement: subparagraph (a) of paragraph 1 of Article 4 defines UAE residence without a “liable to tax” condition, so a free zone company remains a resident for treaty purposes. Claiming the reduced rate still requires a treaty residency certificate, beneficial ownership confirmation and satisfaction of the Article 27 test.

What is the principal purposes test and how does it apply to a UAE structure?

The principal purposes test is set out in Article 27 of the Agreement. A benefit is denied where, having regard to all relevant facts and circumstances, it is reasonable to conclude that obtaining that benefit was one of the principal purposes of any arrangement or transaction that resulted directly or indirectly in it. The evidential threshold is low and it is enough that the benefit was one of several principal purposes. Three Article-specific rules in paragraph 7 of Articles 10, 11 and 12 and the Russian beneficial ownership concept in paragraph 3 of Article 7 of the Russian Tax Code apply in addition.

Can a Russian company apply a 0% rate to dividends received from the UAE?

Yes, from 1 January 2026. Subparagraph 1 of paragraph 3 of Article 284 of the Russian Tax Code grants a 0% rate on a holding of at least 50% held continuously for at least 365 calendar days, but the second paragraph requires that the payer’s State not be on the Russian Ministry of Finance offshore list. For tax periods 2024 to 2026, Article 4 of Federal Law No. 595-FZ of 19 December 2023 directs that provision to the Special List, so the zero rate is opened by Order No. 188n of 22 December 2025, which removed the UAE from the Special List with effect from 1 January 2026; Order No. 187n removed it from the main list on the same date.

Which taxes does the Russia–UAE treaty not cover?

Article 2 contains a list that is exhaustive as at the date of signature: on the UAE side, income tax and corporate tax; on the Russian side, the tax on profits of organizations, the tax on income of individuals, tax on property of enterprises and tax on property of individuals. Value added tax, social insurance contributions and customs duties fall outside it, so a Russian purchaser’s VAT withholding obligations on services acquired from an Emirati company remain in full.

What happens if a company is treated as tax resident in both Russia and the UAE?

Paragraph 3 of Article 4 refers the question to the competent authorities, which shall endeavour to determine residence by mutual agreement having regard to the head or main office, the place of effective management, the place of incorporation and other relevant factors. There is no automatic criterion. Until agreement is reached, no relief or exemption under the Agreement is available except to the extent and in the manner the competent authorities may agree.

Has the 2011 agreement ceased to have effect?

Yes. Paragraph 2 of Article 31 terminates the Agreement of 7 December 2011 on the Taxation of Income from Investments of the Contracting States and their Financial and Investment Institutions from the date the new treaty takes effect, that is, from 1 January 2026. The earlier treaty covered only investment income of the States themselves and their financial and investment institutions and did not extend to private business. ## Key Takeaways

The Agreement applies from 1 January 2026, not from the entry-into-force date of 18 July 2025.Payments made in 2025 remain subject to domestic rates.

The 10% rate covers dividends, interest and royalties with no participation threshold and no second tier. A zero rate is reserved for the Contracting States and the public institutions listed in the Protocol.

Royalties include computer software and the leasing of industrial, commercial and scientific equipment. The second limb is rare in modern treaties and is frequently missed.

Article 21 allocates other income to the source State with no rate ceiling. That reverses the OECD Model and makes classifying every payment a mandatory step.

Services create a permanent establishment after more than 6 months in aggregate within any 12-month period. A construction site takes more than 12 months.

Where a company is dual resident, no relief is available at all until the competent authorities agree. The Agreement contains no automatic place-of-effective-management tie-breaker.

The reduced rate requires both a UAE residency certificate issued for treaty purposes and a beneficial ownership confirmation, obtained before the payment date. No apostille is needed; a Russian translation is.

The CFC rules survive, and the UAE’s departure from the offshore lists does not disapply them. The effective-rate exemption fails at the Emirati 9%, and from 2026 the active foreign holding company exemption requires a rate of not less than 15%.

From 1 January 2026 a Russian company can receive UAE dividends at a 0% rate on a holding of at least 50% held for at least 365 calendar days. This follows from the removal of the UAE from the Special List by Ministry of Finance Order No. 188n: for tax periods 2024 to 2026, subparagraph 1 of paragraph 3 of Article 284 of the Russian Tax Code refers to that list by virtue of Article 4 of Federal Law No. 595-FZ of 19 December 2023.

The Article 27 principal purposes test applies to each item of income separately and requires only that a conclusion be reasonable. A structure without functions, staff and risk does not pass it.

Summary 

The Agreement between the Government of the United Arab Emirates and the Government of the Russian Federation for the Elimination of Double Taxation with Respect to Taxes on Income and on Capital and the Prevention of Tax Evasion and Avoidance was signed in Abu Dhabi on 17 February 2025, ratified by Russian Federal Law No. 189-FZ of 7 July 2025, entered into force on 18 July 2025 and applies from 1 January 2026: to withholding taxes on amounts paid or credited on or after that date, and to other taxes on income for tax periods beginning on or after it. The maximum source-State rate is 10% for dividends (Article 10(1)), 10% for interest (Article 11(1)) and 10% for royalties (Article 12(1)), with no participation threshold; a zero rate applies only to payments to a Contracting State or its financial and investment institutions listed in paragraph 1 of the Protocol. Absent the treaty the Russian domestic rates would be 15% on dividends (Article 284(3)(3) of the Russian Tax Code) and 25% on interest, royalties and services supplied to related parties (Article 284(2)(1) and Article 309(1)(9.4)). A permanent establishment arises from a building site lasting more than 12 months and from services lasting more than 6 months in aggregate within any 12-month period (Article 5(3)). Gains on shares are taxable in the source State where at least 50% of their value was derived, directly or indirectly, from immovable property there at any time during the 365 days preceding the alienation, except for listed shares held at 5% or less of the class (Article 13(4) and (5)). Article 21 allocates other income to the source State with no rate ceiling. Paragraph 4 of the Protocol treats remote employment and remote services under a contract with a resident of a State as exercised in that State irrespective of physical presence. Paragraph 6 of the Protocol removes any requirement for legalisation or apostille on a certificate of residence. Article 27 contains a principal purposes test, and paragraph 7 of each of Articles 10, 11 and 12 contains a further anti-abuse rule. Dual corporate residence under Article 4(3) is resolved only by mutual agreement of the competent authorities, and until then no benefits are granted. Double taxation is relieved by credit only (Article 23). The 2011 agreement of 7 December 2011 ceased to have effect on 1 January 2026. By Russian Ministry of Finance Orders No. 187n and No. 188n of 22 December 2025 the UAE was removed, with effect from 1 January 2026, from the List of Offshore Zones (Order No. 86n, item 38) and from the Special List of Offshore Zones (Order No. 35n, item 20), and the 0% Russian rate on dividends received from the UAE on a holding of at least 50% held for at least 365 calendar days is opened by the removal from the Special List, because for tax periods 2024 to 2026 subparagraph 1 of paragraph 3 of Article 284 of the Russian Tax Code refers to that list under Article 4 of Federal Law No. 595-FZ of 19 December 2023. Article 30 of the Agreement carves hydrocarbon income and related activities out of the treaty entirely. The controlled foreign company rules are preserved by paragraph 5 of the Protocol: the CFC profit inclusion threshold is RUB 10,000,000, the effective-rate exemption requires at least 75% of the weighted average Russian rate, and from 2026 the active foreign holding company exemption requires a rate of not less than 15%, whereas UAE corporate tax is 9% above a threshold of AED 375,000.

Sources

1.       Agreement between the Government of the Russian Federation and the Government of the United Arab Emirates for the Elimination of Double Taxation with Respect to Taxes on Income and on Capital and the Prevention of Tax Evasion and Avoidance of 17.02.2025 — Russian official publication — Official Internet Portal of Legal Information, publication number 0001202507250004, published 25.07.2025.

2.       Agreement between the Government of the United Arab Emirates and the Government of the Russian Federation — English text published by the UAE Ministry of Finance.

3.       Federal Law No. 189-FZ of 07.07.2025 ratifying the Agreement — publication number 0001202507070009.

4.       Information Notice of the Russian Ministry of Finance of 03.12.2025 on the entry into force of the Agreement with the UAE — “International Tax Relations” section of the Ministry of Finance website.

5.       Order No. 187n of the Russian Ministry of Finance of 22.12.2025 repealing item 38 of the List of Offshore Zones — registered with the Ministry of Justice on 26.12.2025 under No. 84815.

6.       Order No. 188n of the Russian Ministry of Finance of 22.12.2025 repealing item 20 of the Special List of Offshore Zones — registered with the Ministry of Justice on 26.12.2025 under No. 84811.

7.       Order No. 86n of the Russian Ministry of Finance of 05.06.2023 approving the List of Offshore Zones — registered with the Ministry of Justice on 15.06.2023 under No. 73846.

8.       Order No. 35n of the Russian Ministry of Finance of 28.03.2024 approving the Special List of Offshore Zones — registered with the Ministry of Justice on 26.04.2024 under No. 78026.

9.       Order No. ED-7-17/914@ of the Russian Federal Tax Service of 30.10.2024 approving the List of States that Do Not Exchange Tax Information with the Russian Federation — registered with the Ministry of Justice on 20.12.2024 under No. 80647.

10.    Order No. ED-7-17/883@ of the Russian Federal Tax Service of 14.10.2025 approving the List of States with which Automatic Exchange of Financial Information Is Carried Out — registered with the Ministry of Justice on 10.12.2025 under No. 84545.

11.    Federal Tax Service of Russia, news release of 07.07.2025 on ratification of the treaty with the UAE.

12.    Russian Tax Code, Article 7, International Treaties on Taxation.

13.    Russian Tax Code, Article 25.13-1, Exemption of the Profit of a Controlled Foreign Company.

14.    Russian Tax Code, Article 25.15, Rules for Including the Profit of a Controlled Foreign Company.

15.    Russian Tax Code, Article 208, Income from Sources in the Russian Federation.

16.    Russian Tax Code, Article 224, Tax Rates.

17.    Russian Tax Code, Article 232, Elimination of Double Taxation.

18.    Russian Tax Code, Article 246.2, Organisations Recognised as Russian Tax Residents.

19.    Russian Tax Code, Article 284, Tax Rates.

20.    Russian Tax Code, Article 309, Taxation of Foreign Organisations Not Operating Through a Permanent Establishment.

21.    Russian Tax Code, Article 312, Special Provisions.

22.    Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses and its amendments, consolidated text — UAE Ministry of Finance.

23.    Cabinet Decision No. 116 of 2022 on the Annual Taxable Income Subject to Corporate Tax — UAE Ministry of Finance.

24.    Cabinet Decision No. 85 of 2022 on Determination of Tax Residency — UAE Federal Tax Authority.

25.    Ministerial Decision No. 247 of 2023 on the Issuance of Tax Residency Certificate for the Purposes of International Agreements — UAE Ministry of Finance.

26.    Cabinet Decision No. 100 of 2023 on Determining Qualifying Income for the Qualifying Free Zone Person — UAE Ministry of Finance.

27.    Ministerial Decision No. 229 of 2025 Regarding Qualifying Activities and Excluded Activities — UAE Ministry of Finance.

28.    UAE Domestic Minimum Top-up Tax — official page of the UAE Ministry of Finance.

29.    Corporate Tax General Guide (CTGGCT1) (edition of 10.09.2023, the version published by the regulator) — UAE Federal Tax Authority.

30.    Federal Law No. 595-FZ of 19.12.2023 amending Parts One and Two of the Russian Tax Code and Article 9 of the Federal Law amending Parts One and Two of the Russian Tax Code and certain legislative acts — Article 4 on the special list of offshore zones for tax periods 2024 to 2026 — publication number 0001202312190001, published 19.12.2023.

31.    Russian Tax Code, Article 123, Failure by a Withholding Agent to Withhold or Remit Tax.

32.    Russian Tax Code, Article 129.6, Unlawful Failure to File a Controlled Foreign Company Notice.

33.    Russian Tax Code, Article 269, Rules on the Treatment of Interest on Debt Obligations for Tax Purposes.

34.    UAE Federal Tax Authority service card, “Issuance of Tax Certificates for Tax Residency” (last updated 11 August 2026) — platform, fees, turnaround and document list.

35.    UAE Federal Tax Authority corporate tax legislation register — FTA Decision No. 6 of 2026 (issued 02.06.2026, published 14.07.2026).

36.    Cabinet Decision No. 142 of 2024 on the Imposition of Top-up Tax on Multinational Enterprises (issued 31 December 2024) — UAE Ministry of Finance.

Disclaimer

This material is provided for information purposes only and does not constitute legal, tax, financial, investment or consulting advice. Before acting, obtain individual professional advice that takes account of your specific circumstances, jurisdiction, company status and the current requirements of the relevant regulators.

Information current as at September 2026.