Saturday, 1 June 2013

UAE double taxation treaties and agreements

Information about UAE double taxation treaties and agreements, and a list of countries that have signed double tax treaties with the UAE.

  • First Double Taxation Avoidance Agreement (DTAA) was signed between the UAE and France in 1989 according to WAM news reports, but there was a limited DTAA signed btween India and UAE before that, covering air travel, and there was an agreement signed in 1975 between the Arab Council of Economic Unity according to an Al Tamimi publication on Tax in the UAE.
  • As of 17 October 2012, the UAE has signed and adopted 66 double taxation avoidance agreements. The most recent one was signed with Japan.
  • As of 26 March 2012, the UAE signed DTAA agreements with 63 countries.
  • As of 19 July 2010, the UAE has 52 DTAAs including 9 with Arab countries. The UAE Ministry of Finance (MOF) has also initialed another 15 agreements.
  • As of 24 November 2008, the UAE had DTAAs with 47 countries.

UAE double taxation treaties - what they mean

Agreements are signed between countries to avoid double taxation for reasons which might include the following

  • Individuals are not paying income tax to two governments on income earned in one country.
  • Individuals are not paying income tax on investments to more than one government.
  • Reduction or elimination of taxes paid on dividends and tax-exempt deposits.
  • Exemptions from capital gains taxes (CGT)
  • Agreements can be intended to boost bilateral economic relations.
  • Government investment in another country can take advantage of tax breaks generated by tax agreements.
  • Attract foreign investment and capital inflows to the UAE.
  • Exemption of freight taxes for national airlines and shipping companies.

List of countries that have double tax treaties with the UAE, or are under consideration

Country Agreement or
News Date¹
Status Comments²
Algeria DTAA?
Armenia DTAA?
Austria 22 Sep 2003 DTAA signed
Azerbaijan 30 Oct 2006 Double tax negotiations planned
Bangladesh 04 Nov 2009 Draft agreement signed
Belarus DTAA?
Belgium 29 Jun 1997 DTAA signed
Bosnia & Herzegovina 21 Jan 2004 Agreement initialled covering tax on investments
Brazil 07 Dec 2003 Agreement to negotiate a DTAA
Bulgaria 26 Jun 2007
Canada 10 Jun 2002 DTAA signed covering taxes on income and capital
Chile 15 Oct 2009 DTAA suggested by UAE (WAM report). Unknown if under negotiation.
China 19 Jun 1994 DTAA signed covering income but not capital?
Colombia 18 Oct 2009 DTAA suggested by UAE (WAM report). Unknown if any negotiations in progress.
Czech Republic DTAA?
Egypt DTAA?
Fiji 01 Aug 2012 Initial agreement signed to eliminate double taxation on income.
Finland 27 Feb 1997 DTAA signed
France 29 Nov 1989 DTAA signed for double tax avoidance on income
Germany 31 Mar 1996 DTAA signed covering double tax avoidance on income and capital
Germany 1995 Talks on renewal of DTAA in June 2006
Greece 18 Jan 2010 Avoid double taxation
Greece 04 Jun 2008 Draft agreement to avoid tax on aviation business
Hong Kong 19 Jul 2010 Initial DTAA on commodities and services signed
India 20 Apr 2007 DTAA amended so UAE residents pay CGT on short term investments
India 31 Aug 1993 DTAA signed for double taxation avoidance on income and capital
India 29 Aug 1989 DTAA signed covering income from air transport between UAE and India
Indonesia 30 Jun 1996 DTAA signed covering income, but not capital?
Italy 04 Dec 1995 DTAA signed covering income but not capital?
Japan 17 Oct 2012 Initial agreement to avoid double taxation on income signed
Japan 27 Oct 2008 Third round of talks on double tax concluded
Japan 21 Oct 2007 Third round of talks to avoid double taxation, held in Tokyo
Japan 28 Jun 2004 DTAA signed covering air and sea freight
Jordan 13 Jun 2005 DTAA signed
Kenya 21 Nov 2011 DTAA signed
Korea DTAA?
Latvia 11 Mar 2012 Agreement signed for Avoidance of Double Taxation on Income
Lebanon 15 Nov 1998 DTAA signed, on income only, not capital?
Libya 10 Jun 2010 Initial agreement signed after 2nd round of talks to prevent double taxation
Luxembourg 20 Nov 2005 DTAA signed. Ratified in May 2009, effective 01 January 2010?
Malaysia 30 Jun 1996 DTAA signed covering tax avoidance on income and capital
Malta 13 Mar 2006 DTAA signed
Mauritius DTAA?
Mexico 20 Nov 2012 DTAA signed to avoid double taxation on income
Mongolia DTAA?
Montenegro 26 Mar 2012 DTAA and protection of investments
Morocco 29 Sep 1999 DTAA signed
Mozambique DTAA?
Netherlands 02 Jun 2010 DTAA takes effect covering tax on dividend payments
Netherlands 08 May 2007
Netherlands 27 Apr 1992 DTAA signed for double tax avoidance on income and profits from UAE-Holland air travel
Netherlands Antilles May 2008 First round of negotiations started?
New Zealand DTAA?
Pakistan 24 Jan 1994 DTAA signed for double tax avoidance on income tax
Philippines 22 Sep 2003 DTAA signed
Poland 24 Jan 1994 DTAA signed for double tax avoidance on income tax
Romania 04 Dec 1995 DTAA signed covering capital but not income?
Russia 30 Oct 2006 Double tax negotiations planned
Seychelles DTAA?
Singapore 30 Jun 1997 DTAA signed
Singapore 31 Mar 1990 DTAA signed for income from air transport between UAE and Singapore
South Korea
Spain 06 Mar 2006 DTAA signed
Spain 01 Nov 2005 Agreement initialled, not sealed
Sri Lanka 31 Aug 1993 DTAA for double tax avoidance on income from air transport between UAE and SL
Sudan 12 Apr 2002 Agreement signed to allow tax-free profit repatriation
Switzerland May 1999 DTAA signed
Switzerland 27 Apr 1992 DTAA signed for double tax avoidance on income from air travel between both countries
Syria 28 Jun 2000 DTAA signed
Tajikistan DTAA?
Thailand 29 Nov 2000 DTAA signed
Tunisia 27 Feb 1997 DTAA signed for double tax avoidance on income and capital
Turkey DTAA?
Turkmenistan 30 Nov 1999 DTAA signed
Ukraine DTAA?
Uzbekistan DTAA?
Venezuela 07 Jun 2010 Agreement signed for double tax avoidance, tax evasion prevention, on income and capital
Vietnam Feb 2009
Yemen DTAA?

  1. Might be date agreement signed, or date news released.
  2. If notes say "DTAA signed" it usually means DTAA signed for double tax avoidance and tax evasion prevention on all income and capital sources.

News items related to UAE double taxation agreements

  • 21 Nov 2012 (Mexico, WAM news) - UAE signed a Double Taxation Avoidance Agreement (DTAA) with Mexico on 20 Nov 2012 to avoid double taxation on income.
  • 17 Oct 2012 (Japan) (WAM news):
    • Initial agreement to avoid double taxation on income signed between UAE and Japan.
    • Agreement aims to identify all the recipients of tax and financial benefits that will be covered by the main agreement, including federal government institutions, local and sovereign funds, UAE nationals, and private sector institutions that own investments in Japan.
    • Agreement also exempts national airlines, and other airlines based in the UAE, from taxes.
    • Agreement states that taxes are reduced on dividends from 20% to 5% with a reduction rate of 75% in cases where any UAE institution or company owns 10% capital of any Japanese company; or in cases where companies do not own that percentage, the taxes will be decreased from 20% to 10% with a reduction rate of 50%.
    • Japan will exempt all UAE federal and local government institutions in addition to UAE sovereign funds from 20% tax on interest profits.
    • Japan imposes a 30% tax on capital profits for residents and non-residents, the provisions of this agreement stipulate exemption of capital profits tax which results from owning shares or any interest in a company, including trust funds.
    • The agreement also provided various provisions and a protocol stating that no prohibition or restriction on tax exemptions or reductions will be applied, regardless of current or future local laws or as a result of any bilateral agreement between the two countries or multilateral agreement that either countries takes part in.
    • Both parties agreed to complete the procedures for the final signing of the agreement as soon as possible.
  • 26 March 2012 (Republic of Montenegro) - two agreements signed: on double taxation avoidance, and on protection of investments.
  • 11 March 2011 (Republic of Latvia) - agreement signed for the Avoidance of Double Taxation on Income (WAM report).
  • 21 November 2011 (Kenya) - Double taxation avoidance agreement signed between UAE and Kenya. All UAE national air carriers (Air Arabia, Emirates Airline, Etihad Airways, RAK Airways) exempted from taxes in Kenya. Students, sovereign funds, staff members of airlines, income and capital in both the public and private sectors are also exempted from all taxes. Tax on dividends of the private sector reduced by Kenya from 20% to 5%.
  • 19 July 2010 (Hong Kong) - an initial double taxation avoidance agreement on commodities and services between the UAE and Hong Kong signed by HE Younis Haji Al Khoori, Director General of UAE Ministry of Finance (MOF press release).
  • 10 June 2010 (Libya) - UAE Ministry of Finance signed an initial agreement with Libya to facilitate capital and investment transfer between the two countries, and protect taxpayers against both direct and indirect double taxation by collecting tax in the country of domicile of the investor or business. Agreement was signed at the end of the second round of double tax avoidance negotiations.
  • 07 June 2010 (Venezuela) - UAE Ministry of Finance signed an agreement with Venezuela covering taxes on income and capital, taxes on investments in public and private sectors, and simplifies financial and tax benefits of air and sea carriers. It is reportedly the first double tax agreement between the UAE and a Latin American country (press release 07 June 2010).
  • 02 June 2010 (The Netherlands / Holland) - Treaty for the Avoidance of Double Taxation takes effect. Includes 0% Dutch withholding tax rate for dividends paid to government-owned UAE entities, or a 5% withholding tax for non-government entities (previously 15%) (MOF press release 01 June 2010).
  • 04 November 2009 (Bangladesh) - A draft double taxation agreement signed between the UAE Ministry of Finance (MOF) and Bangladesh which exempts government institutes from any tax on any income, reduces tax on private investment from 17.5% to 5%, and a complete taxation exemption on income derived from aviation related activities (WAM).
  • 18 October 2009 (Colombia) - The UAE Foreign Minister, Shaikh Abdullah Bin Zayed Al Nahyan, met with the Colombian President, Alvaro Uribe, in Bogota. WAM reported that (referring to Sheikh Abdullah) He called for the signing of a cooperation agreement between the two sides to boost trade through agreement to prevent double-taxation and protect investments.
  • 15 October 2009 (Chile) - UAE Minister of Foreign Affairs, Sheikh Abdullah Bin Zayed Al Nahyan, met with President of Chile, Dr Michelle Bachelet, in Santiago. Among issues discussed and conveyance of regards, WAM reported that The UAE Minister of Foreign Affairs underlined the need to sign the Avoiding of Double Taxation and Encourage and Protection of Investment Agreements.
  • 04 June 2008 (Greece) - a draft treaty initialled for the avoidance of taxation on air transportation by national carriers of both Greece and the UAE as part of the first round of negotiations. Round two to commence in September 2008 (WAM).
  • 27 October 2008 (Japan) - Third round of double taxation avoidance talks between the UAE and Japan concluded. Talks begain in the 1990s, an MOU was signed in 2004 or 2005, further talks in November 2006 and March 2007 (WAM).
  • 01 November 2005 (Spain) - a double taxation agreement was initialled between the UAE and Spain, to provide legal framework for promoting investments and benefiting from advanced technology, encourage the flow of capital, and expand the two-way trade volume between the two countries (WAM).
  • June 2004 or 2005 (Japan) - an MOU signed so that Japanese and UAE nationals would not be liable for direct, indirect and local government taxes on trade operations related to air and sea freight (WAM).
  • 07 December 2003 - a press release after the visit of Brazilian President Luiz Inacio Lula da Silva to Abu Dhabi on 06 and 07 December 2003, said With the same objective, the two Governments agreed to negotiate an Agreement on double taxation exemption.

WAM (Emirates News Agency) is the official UAE news agency.

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