India UAE DTAA for Companies in 2026 with Rates, Residency and PPT

Written by Nihal Srivastava, Krystal7 Consultants. Last updated 2 October 2026.

The India UAE DTAA caps Indian tax at 10 percent on dividends and royalties paid to a UAE company. Interest is capped at 12.5 percent, or 5 percent on a bank loan. The treaty has no article on technical fees, so a service fee is business profit, taxable in India only through a permanent establishment. A UAE company qualifies only if it is incorporated in the UAE and managed and controlled wholly there. Each claim needs a UAE tax residency certificate and Form 41 under section 159(8) of the Income Tax Act, 2025.

This page covers residency, rates, service fees, free zone companies, capital gains, the MLI principal purpose test, permanent establishment, UAE corporate tax and documents. It ends with worked examples, a checklist and 16 FAQs. Rupee amounts use Indian grouping: INR 1,00,00,000 is one crore.

What does the India UAE DTAA cover?

The India UAE Double Taxation Avoidance Agreement (DTAA) is the income tax treaty the two countries signed on 29 Apr 1992. It entered into force on 22 Sep 1993, and India notified it by GSR 710(E) of 18 Nov 1993. It decides which country may tax a UAE company's Indian income. It also caps India's rate on dividends, interest and royalties.

Article 2 covers Indian income tax and the UAE's income tax and corporation tax. It also covers "any identical or substantially similar taxes" either country imposes later. On our reading, the UAE corporate tax that started in 2023 falls inside that clause. Two later protocols, signed on 26 Mar 2007 and 16 Apr 2012, and the Multilateral Instrument (MLI) have amended the treaty.

Instrument	Dates	What it did
Agreement, GSR 710(E)	Signed 29 Apr 1992; in force 22 Sep 1993; notified 18 Nov 1993	Original treaty and protocol
First protocol, S.O. 2001(E)	Signed 26 Mar 2007; notified 28 Nov 2007	Substituted Article 4(1) with the present residence test for UAE companies; 10% dividend cap in Article 10(2); new paragraphs 3 to 5 of Article 13 on share gains; new Article 29 on limitation of benefits
Second protocol, Notification No. 29/2013	Signed 16 Apr 2012; notified 12 Apr 2013, with retrospective effect from 12 Mar 2013	Substituted Article 28 on exchange of information and Article 31 on entry into force
MLI	In force for the UAE 1 Sep 2019 and India 1 Oct 2019	New preamble; principal purpose test replaces Article 29; three year MAP window; corresponding adjustments

Source: India UAE DTAA and the MLI synthesised text on incometaxindia.gov.in, read 2 Oct 2026. The synthesised text gives the signing dates of both protocols. Neither page states the date from which the 2007 protocol took effect in India. For a payment from that period, read notification S.O. 2001(E) of 28 Nov 2007 in the Gazette.

From 1 Apr 2026, section 159 of the Income Tax Act, 2025 gives effect to the treaty. It replaced section 90 of the 1961 Act. Under section 159(4), the Act applies only where it is more beneficial to the taxpayer. Section 159(6) still applies the General Anti Avoidance Rule (GAAR) in Chapter XI, even where the treaty is more beneficial.

The treaty has 32 articles. Three differ from most of India's treaties and shape every UAE claim we review:

1. Article 4(1)(b). A UAE company must be incorporated in the UAE and "managed and controlled wholly in UAE".
2. Article 12. It covers royalties only. There is no clause for fees for technical services.
3. Article 22. Income the treaty does not mention is "taxable only" in the country of residence. The exception is income connected with a PE in the other country.

If the Indian company is not yet set up, start with our guide to company registration in India from the UAE.

Who is a resident of the UAE under the India UAE DTAA?

A company is a UAE resident under Article 4(1)(b) only if it "is incorporated in the UAE and which is managed and controlled wholly in UAE". Both limbs must hold. A UAE company whose board sits in India, or whose key decisions are taken in India, fails the second limb and gets no treaty relief.

This wording came with the 2007 protocol, which substituted paragraph 1 of Article 4. The test does not ask whether the company is liable to tax in the UAE. India's own limb in Article 4(1)(a) does use a "liable to tax" test. For individuals, the UAE limb asks for presence in the UAE of at least 183 days in the calendar year.

Person	Article	UAE residence test	What breaks it
Company	4(1)(b)	Incorporated in the UAE and managed and controlled wholly in the UAE	Board meetings or key decisions in India or a third country
Individual	4(1)(b)	Present in the UAE at least 183 days in the calendar year	Fewer days; tie breaker in Article 4(3) if also Indian resident
UAE Government, political sub divisions, local authorities and named government institutions	4(2)	Resident by status	Not applicable
Company resident in both countries	4(4)	Resident where its place of effective management is	Decisions taken in India

Source: India UAE DTAA, Article 4, as amended by S.O. 2001(E).

"Wholly" is a strict word. We read it as every board meeting and every director decision taken in the UAE. Nobody in India should hold standing authority to decide for the company. A single board resolution signed in Gurugram can hand a tax officer an argument.

Indian law adds a second risk. Section 6(10)(a) of the Income Tax Act, 2025 makes a company resident in India if its place of effective management is in India. Section 6(10)(b) defines that as where "key management and commercial decisions" are "in substance, made". A UAE company run by Indian resident promoters from India can become an Indian resident. Then India taxes its worldwide income at the foreign company rate.

Article 4(4) breaks a dual residence tie for companies by place of effective management. That test lands in the same place as section 6(10). So the fix for both risks is one fix: take the decisions in the UAE and keep the minutes that prove it.

What withholding rates apply under the India UAE treaty?

The treaty caps India's tax at 10 percent on dividends to a UAE beneficial owner, with no minimum holding. Interest is capped at 5 percent on a loan from a bank or similar financial institution and 12.5 percent in other cases. Royalties are capped at 10 percent. Interest beneficially owned by the UAE Government or Central Bank is exempt.

Income from India	Article	Treaty cap	Condition	Domestic rate for a foreign company, tax year 2026-27 (before surcharge and cess)
Dividends	10(2)	10%	Beneficial owner; any holding size	20%, section 207(1)
Interest on a loan granted by a bank or similar financial institution	11(2)(a)	5%	Beneficial owner; bona fide banking business	20% on foreign currency loans; 35% on rupee loans
Interest from other lenders, such as a parent	11(2)(b)	12.5%	Beneficial owner	20% on foreign currency loans; 35% on rupee loans
Interest to the UAE Government, a political sub division, a local authority or the Central Bank	11(3)	Exempt	Derived and beneficially owned by that body	Exempt under the treaty
Royalties, including equipment rentals	12(2)	10%	Beneficial owner	20%, section 207(2)
Fees for technical, managerial or consultancy services	7, or 14	Nil without a PE or fixed base	No PE in India; Article 12 has no FTS clause	20%, section 207(2)
Gains on shares of an Indian company	13(4)	No cap	None	12.5% long term, 35% short term (unlisted)
Income not dealt with elsewhere	22	Taxable only in the UAE	Not connected with an Indian PE	Rate in force

Sources: India UAE DTAA; sections 197 and 207 of the Income Tax Act, 2025; Finance Act, 2026, First Schedule.

The Indian payer deducts under section 393(2), Table serial 17, at the "rates in force". That is the Finance Act rate or the treaty rate, as applicable. A payer holding the treaty documents deducts at the lower treaty rate. Our guide to TDS on payments to non residents covers the mechanics.

Domestic rate against treaty rate

Domestic rates carry surcharge and 4 percent Health and Education Cess. A foreign company's surcharge is 2 percent above INR 1,00,00,000 of income paid or likely to be paid in the year. It is 5 percent above INR 10,00,00,000. Add up dividends, interest and royalties to one payee before you pick the slab.

In the 2 percent slab, a 20 percent base rate becomes 21.216 percent and a 35 percent base rate becomes 37.128 percent. A 12.5 percent long term gain rate becomes 13.26 percent.

We apply the treaty rate flat, without surcharge or cess. Tribunal rulings support that reading, but no CBDT circular settles the point. So Form 146 should state the article and the flat rate.

Rupee interest shows the widest gap: 35 percent at home against a 12.5 percent treaty cap. The 5 percent rate in serial 2 of section 393(2) covers only foreign currency borrowings from 1 Jul 2012 to 30 Jun 2023. See our note on an ECB loan from a foreign parent.

Each cap has a permanent establishment carve out. Article 10(4) and Article 12(4) remove the cap where the holding or the right is connected with an Indian PE or fixed base. The income is then taxed under Article 7 or Article 14. Our dividend guide covers the company law side of paying a UAE parent.

What counts as a royalty under Article 12

Article 12(3) defines royalties widely. It covers copyrights, patents, trade marks, designs, plans, secret formulas and processes. It also covers "the use of, or the right to use, industrial, commercial or scientific equipment". So a UAE company leasing machinery or equipment to an Indian company earns a royalty under this treaty, capped at 10 percent.

The definition also covers "information concerning industrial, commercial or scientific experience". It excludes payments for mines, quarries, petroleum and other natural resources. Article 12(6) applies the cap only to an arm's length amount between related parties. Any excess stays taxable under each country's own law.

How are technical and management fees taxed when the treaty has no FTS article?

The India UAE treaty has no clause for fees for technical services. A technical, managerial or consultancy fee paid to a UAE company is therefore business profit under Article 7. India may tax it only if the UAE company has a PE in India and the fee is attributable to that PE.

This is the biggest practical difference from treaties such as the India Singapore DTAA, the UK or the US. Those treaties let India tax technical fees at 10 or 15 percent at source. Indian domestic law is wider still. Section 9(7) of the Income Tax Act, 2025 treats almost any technical or consultancy fee paid by an Indian resident as Indian income. Section 159(4) lets the UAE company use the treaty instead.

Service from a UAE company to an Indian company	Treaty route, on our reading	Indian tax without a PE	What we keep on file
Group finance, HR and legal support from Dubai	Article 7 business profit	Nil	Service logs; staff days in India
Engineering design delivered by email	Article 7 business profit	Nil	Deliverables; proof of work done in the UAE
Licence of software, patents or know how	Article 12 royalty	10%	Licence agreement; arm's length support
Lease of equipment used in India	Article 12 royalty	10%	Lease agreement; asset register
Consultants on site in India for over 9 months on one project	Article 5(2)(i) service PE	Profit attributable to the PE, at 35% plus surcharge and cess	Day counts by project
Guarantee commission or other item not named in the treaty	Article 22, taxable only in the UAE	Nil without a PE	Written treaty analysis

Source: India UAE DTAA, Articles 5, 7, 12, 14 and 22; our reading for the classification column.

Article 14 needs a second look. It covers "professional services or other independent activities of a similar character". India may tax such income where the provider has a fixed base regularly available in India. It may also tax it where the provider stays in India 183 days or more in the year. We see tax officers test consultancy firms under Article 14. So we track both the Article 5 and the Article 14 day counts.

A fee outside the royalty definition still goes on Form 145, in Part D, with a written treaty analysis on file. Form 145 and Form 146 replaced Forms 15CA and 15CB from 1 Apr 2026. Our Form 15CA and 15CB guide explains the parts.

Watch the boundary with royalties. A service that hands over a secret process, a design or know how can be "information concerning industrial, commercial or scientific experience". That is a royalty at 10 percent. We ask the UAE team what the Indian staff receive: a service performed for them, or knowledge they keep and reuse.

Can a UAE free zone company claim the treaty?

Yes, if it meets Article 4(1)(b). A free zone company is incorporated in the UAE under the law of its free zone. UAE corporate tax law also treats a free zone person as a UAE resident. The treaty then asks only one more question: whether the company is managed and controlled wholly in the UAE.

The treaty text does not separate mainland and free zone companies. On our reading, nothing in Article 4 denies relief to a free zone company because it pays 0 percent UAE tax on qualifying income. The UAE limb of Article 4 has no "liable to tax" test. The principal purpose test and GAAR still apply to the arrangement, as they do to any UAE company.

The UAE side has its own rules. Article 11(3)(a) of Federal Decree Law No. 47 of 2022 makes a company incorporated in the UAE, "including a Free Zone Person", a resident person. A Qualifying Free Zone Person (QFZP) pays 0 percent on qualifying income and 9 percent on other taxable income under Article 3(2).

QFZP condition	Rule	Why it matters for Indian income
Maintain adequate substance in the UAE	Article 18, Federal Decree Law No. 47 of 2022	Supports Article 4(1)(b) and the PPT in India
Derive qualifying income	Article 18; Cabinet Decision No. 100 of 2023	Decides whether Indian dividends, interest or royalties bear 0 or 9 percent in the UAE
Not elect to be taxed at the standard rate	Article 18	Election moves all income to the 9 percent rate
Comply with transfer pricing rules	Article 18	Pricing with the Indian subsidiary must be arm's length in both countries
Non qualifying revenue at most 5% of total revenue or AED 5,000,000, whichever is lower	Article 3, Ministerial Decision No. 229 of 2025	Large non qualifying Indian income can cost QFZP status
Profits of a PE outside the free zone, in the UAE or abroad	FTA guide on free zone persons, 26 May 2024	An Indian PE's profits bear 9 percent in the UAE

Sources: Federal Decree Law No. 47 of 2022 as amended; Cabinet Decision No. 100 of 2023; Ministerial Decision No. 229 of 2025; Federal Tax Authority.

Ministerial Decision No. 229 of 2025, issued 28 Aug 2025, lists the qualifying activities. It repealed Ministerial Decision No. 265 of 2023 with effect from 1 Jun 2023. The list includes "Holding of shares and other securities for investment purposes" and "Headquarter services to Related Parties". It also includes treasury and financing services to related parties.

So a free zone holding company can earn Indian dividends inside the 0 percent band. A free zone company billing an Indian subsidiary for headquarter services may also qualify. Confirm each stream with a UAE adviser before you set the structure. Indian tax at source follows the treaty, whatever rate the UAE charges.

How are capital gains on Indian shares taxed for a UAE company?

India may tax a UAE company's gain on shares of an Indian company under Article 13(4), at the full domestic rate. The 2007 protocol added this paragraph. The treaty has no grandfathering for older holdings. Unlisted shares held over 24 months give long term gains at 12.5 percent under section 197, plus surcharge and cess.

The protocol substituted paragraphs 3, 4 and 5 for the single paragraph 3 of the 1992 text. Unlike the Mauritius and Singapore treaties, it kept no exemption for shares bought before a cut off date.

Property sold by a UAE company	Article	Who may tax	Our note
Immovable property in India	13(1)	India	Domestic rate applies
Movable property of an Indian PE or fixed base	13(2)	India	Taxed with the PE
Shares of a company whose property is principally Indian immovable property	13(3)	India	Look through test, "directly or indirectly"
Other shares of an Indian company	13(4)	India	Any holding size and any acquisition date
Debentures, bonds and other property	13(5)	UAE only	Principal purpose test and GAAR still apply
Shares of a UAE company owning an Indian subsidiary	13(5), on our reading	UAE only	Article 13(4) covers shares of an Indian resident company only; the PPT and GAAR still apply

Source: India UAE DTAA, Article 13, paragraphs 3 to 5 as substituted by S.O. 2001(E).

Where India taxes the gain, domestic rules apply in full. Section 197(4) computes a foreign company's gain on unlisted securities in rupees, without the foreign currency method in section 72(6). Short term gains on unlisted shares bear 35 percent. Surcharge and cess apply on top.

A resident buyer withholds under section 393(2), serial 17, on the sum chargeable. The buyer often wants a certificate in Form 128 to fix the amount. Our note on lower TDS certificates covers that application.

Buy backs changed in 2026. The Finance Act, 2026 taxes buy back consideration as a capital gain from 1 Apr 2026. On our reading, Article 13(4) now decides India's right to tax a buy back from a UAE parent, with no cap. Before, it was a deemed dividend under Article 10, capped at 10 percent.

A promoter also bears extra tax under section 69. For an unlisted company, a promoter includes any holder above 10 percent. Our note on share transfers between residents and non residents covers the FEMA side of a sale.

How do the MLI and the principal purpose test apply to the India UAE treaty?

The MLI replaced Article 29 of the treaty with the principal purpose test (PPT) in MLI Article 7(1). The PPT denies a benefit where obtaining it was one of the principal purposes of an arrangement. The exception is where granting it fits the treaty's object and purpose. For Indian taxes it applies from 1 Apr 2020.

The old Article 29 looked at "the main purpose or one of the main purposes of the creation of such entity". It added that legal entities "not having bona fide business activities" were covered. The synthesised text states that paragraph 1 of Article 7 of the MLI replaces Article 29 of the Agreement.

The PPT reaches further. It asks about "any arrangement or transaction", beyond why the entity was created. The officer must find it "reasonable to conclude, having regard to all relevant facts and circumstances". So a long established UAE company can still lose relief on one transaction.

MLI provision	In the India UAE synthesised text?	Effect
Article 6, preamble	Yes	Treaty reads against non taxation and treaty shopping
Article 7(1), principal purpose test	Yes, replaces Article 29	Any benefit can be denied: rates, exemptions and PE rules
Article 16, mutual agreement procedure	Yes	Case may be presented within three years of the first notification, up from two years in Article 27
Article 17, corresponding adjustments	Yes	The other country makes an appropriate adjustment after a transfer pricing change
Articles 4, 8, 9 and 12 to 15	No box in the synthesised text	Article 4 tie breaker, Article 10, Article 13 and Article 5 stay as negotiated

Source: synthesised text of the India UAE DTAA on incometaxindia.gov.in, which "does not constitute a source of law".

For India, the MLI applies to tax withheld at source on amounts paid or credited from 1 Apr 2020. It applies to other Indian taxes for periods beginning on or after that date. For the UAE, withholding taxes follow from 1 Jan 2020 and other taxes from periods beginning on or after 1 Apr 2020.

CBDT Circular No. 01/2025 of 21 Jan 2025 guides officers on the PPT. It names three treaties whose grandfathering stays outside the PPT: Cyprus, Mauritius and Singapore. The UAE treaty is not on that list, and it has no grandfathering to protect. The circular asks for "an objective assessment of the relevant facts and circumstances", case by case.

Officers may refer to the UN Model Commentary on Articles 1 and 29 (2021 update) and the BEPS Action 6 report. Section 536 of the Income Tax Act, 2025 keeps such circulars alive where they are consistent with the new Act.

Does GAAR apply to a UAE holding company?

Yes. Section 159(6) of the Income Tax Act, 2025 applies GAAR in Chapter XI even where the treaty is more beneficial. Rule 128 of the Income Tax Rules, 2026, as amended, carves out one item. That is income on the transfer of investments made before 1 Apr 2017. Every other UAE claim faces GAAR.

CBDT amended the GAAR rules on 31 Mar 2026:

1. Notification No. 54/2026 (G.S.R. 240(E)). The Income Tax (Tenth Amendment) Rules, 2026 amended rule 10U of the Income Tax Rules, 1962, from publication.
2. Notification No. 55/2026 (G.S.R. 241(E)). The Income Tax (Amendment) Rules, 2026 amended rule 128 of the Income Tax Rules, 2026, from 1 Apr 2026.

The rule 128 carve out matters less for UAE holdings than for Mauritius or Singapore ones. The treaty has no grandfathered exemption, so India taxes the gain on old UAE holdings anyway. The carve out only stops GAAR from adding to that tax.

In Tiger Global (2026 INSC 60, 15 Jan 2026) the Supreme Court allowed the revenue's appeals and set aside the Delhi High Court judgment. It is a Mauritius treaty case. Commentators read the ruling as limiting reliance on a tax residency certificate alone. Read the judgment itself before relying on any summary of it for a UAE structure.

On our reading, every UAE claim now faces three tests beyond the certificate: managed and controlled wholly in the UAE, the PPT and GAAR. No route accepts a tax residency certificate alone. Dividend, interest and royalty claims also need beneficial ownership under Articles 10(2), 11(2) and 12(2).

When does a UAE company have a permanent establishment in India?

A UAE company has a permanent establishment (PE) in India if it has a fixed place of business here. A building, construction or assembly project, or supervision of one, counts after 9 months. Services, including consultancy, create a PE after 9 months on the same or a connected project within any twelve month period.

PE trigger	Article	Threshold	Typical risk for a UAE parent
Fixed place of business: place of management, branch, office, factory, workshop	5(1), 5(2)	No day count in the text	Parent staff using a room in the Indian office as their own
Building site, construction or assembly project, or supervisory activities	5(2)(h)	More than 9 months	Plant set up, or a build supervised, for the Indian company
Furnishing of services, including consultancy services	5(2)(i)	More than 9 months in aggregate within any twelve month period, same or connected project	Consultants on long assignments in India
Dependent agent	5(4)	Habitually exercises authority to conclude contracts for the enterprise	Indian staff negotiating and closing deals for the parent
Agent devoted wholly to the enterprise	5(5)	Not treated as independent	Indian distributor tied to the group
Storage, display, delivery, purchasing or preparatory and auxiliary place	5(3)	Not a PE	Purchasing or information work only

Source: India UAE DTAA, Article 5.

The UAE treaty has no 30 day rule for related enterprises, unlike the Singapore treaty. The 9 month service test runs per project, across connected projects, within a rolling twelve month window. Short visits by parent staff rarely cross it. Long secondments and on site implementation teams do.

A PE changes the regime. Article 7 attributes profit to the PE, and Article 7(3) allows its expenses, including executive and general administrative costs. India taxes that profit at the foreign company rate of 35 percent, plus surcharge and cess, through a return. Royalties connected with the PE move to section 59 of the 2025 Act (old section 44DA), with an accountant's report.

The PE also hurts on the UAE side. The FTA says a QFZP's profits attributable to a PE in a foreign country bear 9 percent UAE corporate tax. Our guide on how to avoid permanent establishment risk covers the controls.

A UAE company choosing between a branch and a subsidiary in India faces the PE question at the start. Our comparison of a branch office and a subsidiary for a UAE company sets out both.

How does UAE corporate tax affect treaty planning?

UAE corporate tax applies for financial years starting on or after 1 Jun 2023, under Federal Decree Law No. 47 of 2022. The rate is 0 percent on taxable income up to AED 375,000 and 9 percent above it. Qualifying Free Zone Persons pay 0 percent on qualifying income. Large groups face a 15 percent domestic minimum top up tax from 2025.

The UAE no longer offers a zero tax result by default. So a UAE company with Indian income must choose its income streams, where to book them and how much substance to keep.

UAE rule	Source	Effect on Indian income
9% corporate tax above AED 375,000	Federal Decree Law No. 47 of 2022, Article 3; u.ae	Royalties and interest from India can bear UAE tax after Indian withholding
0% on qualifying income of a QFZP	Article 3(2) and Article 18	Indian dividends and some related party services may stay at 0%
Participation exemption for holdings of 5% or more, held or intended to be held for at least 12 months, in a company taxed at not less than 9%	Article 23	Indian dividends and share gains may be exempt in the UAE
Foreign tax credit, capped at UAE tax due on that income	Article 47	Indian TDS on royalties and interest reduces UAE tax
0% withholding tax on UAE source payments to non residents	Article 45; Ministry of Finance	A UAE company pays dividends to an Indian parent without UAE tax
Domestic minimum top up tax for groups with revenue of EUR 750 million or more in at least two of the four prior financial years	Ministry of Finance, Top up Tax page; financial years from 1 Jan 2025	A 0% UAE outcome for a large group is topped up to 15%
Economic substance reports cancelled for financial years ending after 31 Dec 2022	Cabinet Decision No. 98 of 2024, announced 14 Oct 2024	Substance still matters for QFZP status, the TRC and India's PPT

Sources: Ministry of Finance UAE; Federal Decree Law No. 47 of 2022 as amended (unofficial translation, January 2026); u.ae.

Three points follow for planning.

1. Dividends. India withholds 10 percent. An Indian subsidiary paying corporate tax at 22 percent under section 200 (old 115BAA) clears the 9 percent subject to tax test, on our reading. So the dividend can be exempt in the UAE under Article 23.
2. Royalties and interest. India withholds 10 or 12.5 percent. A mainland UAE company then pays 9 percent UAE tax, less a foreign tax credit under Article 47. The Indian tax usually covers the UAE tax on that income in full.
3. Service fees. India withholds nothing without a PE. The UAE company pays 9 percent, or 0 percent if it is a QFZP and the service is a qualifying activity.

Which documents does a UAE company need to claim treaty benefits?

Section 159(8) of the Income Tax Act, 2025 needs two things. One is a tax residency certificate (TRC) from the UAE Government. The other is Form 41, filed online under rule 75. The UAE Federal Tax Authority (FTA) issues the TRC. The Indian payer also wants a PAN or rule 217 details, declarations and a chartered accountant's Form 146.

Document	Issued or filed by	What it supports	Timing
UAE tax residency certificate	Federal Tax Authority	Section 159(8)(a); Article 4	Must cover the date of credit or payment
Form 41 (old Form 10F)	UAE company, online, verified by EVC, DSC or OTP	Section 159(8)(b); rule 75	Once per tax year, before the first payment
PAN, or the six rule 217 details	UAE company	Avoids the higher rate under section 397(2)	Before tax is deducted
Board minutes showing decisions taken in the UAE	UAE company	Article 4(1)(b) "managed and controlled wholly"	Each year, and for each dividend or loan decision
Beneficial ownership declaration, with the share register	UAE company and Indian company	Articles 10(2), 11(2) and 12(2)	Each year, and on each dividend date
No PE declaration, with staff day counts by project	UAE company	Articles 5, 7, 10(4) and 12(4)	Each year, updated on any change
Service or licence agreement	Both companies	Articles 7 and 12	Before the first invoice
Form 146 (old 15CB), then Form 145 (old 15CA)	Chartered accountant, then Indian company	Rate and article examined; remittance information	Before the money leaves India
Form 131 (old 16A)	Indian company, from TRACES	Credit for Indian tax	Within 15 days of the Form 144 due date

Getting a UAE tax residency certificate

The FTA service page sets the rules for companies. A legal person "must have been established in the UAE for at least one year". It files its trade licence and the other documents the page lists. It also needs "audited financial accounts certified by a certified audit firm" and a local bank statement covering 6 months within the financial year.

FTA TRC point	What the FTA page says	What it means for an Indian claim
Minimum age of the company	Established in the UAE for at least one year	A new UAE holding company cannot get a TRC in its first year
Validity	"valid for one year from the beginning of the financial year selected by the applicant"	A calendar year UAE company needs two certificates to cover India's April to March tax year
Fee for a non tax registrant legal person	AED 1,750	Tax registrants pay AED 500
Processing time	3 business days; 7 business days with a hard copy; 5 working days with tax form attestation	Apply before the Indian payment date
Legal basis for treaty certificates	Ministerial Decision No. 247 of 2023, issued 16 Oct 2023, effective 1 Mar 2023	A person meeting the treaty's residence conditions may apply

Source: Federal Tax Authority, Issuance of Tax Residency Certificate (TRC), read 2 Oct 2026; Ministerial Decision No. 247 of 2023.

Plan the first Indian payment after the UAE company can get its certificate. Until then India deducts at the domestic rate.

Form 41 and the Indian payer's file

The Form 41 guidance note says the form is filed "only once in a tax year" and PAN is optional. It also says: "Benefit of DTAA is available only with filing of Form 41." A filer without a PAN verifies by OTP. Still, the UAE company needs a PAN for the Indian return a treaty rate triggers, and for a downloadable Form 131.

Rule 217 lists six details that stop the higher rate under section 397(2). They are name, email, phone number, address in the UAE, the TRC and the UAE tax identification number. For a UAE company we use its corporate tax registration number, where it has one.

If the TRC is late, deduct at the domestic rate, and the UAE company claims the excess through its Indian return. The alternative is a lower deduction certificate in Form 128 under section 395(1). With it, the payer files Form 145 in Part B and needs no Form 146.

What substance should a UAE company show?

A UAE company should show that it is managed and controlled wholly in the UAE and that it runs a real business there. The treaty sets no spending number, unlike Article 24A of the Singapore treaty. The tests are qualitative: Article 4(1)(b), the PPT, GAAR, Indian residence and, for free zones, QFZP substance. The points below are our practice.

Area	What we look for	Rule it supports
Board	Directors who live in the UAE, with the knowledge to run the Indian investment	Article 4(1)(b); section 6(10); PPT
Decisions	Dividends, fees, funding and exits decided and minuted in the UAE before the Indian company acts	Article 4(1)(b); place of effective management
People	Employees in the UAE with real roles, such as treasury, regional sales or IP management	PPT; QFZP adequate substance
Premises	An office in the UAE that the company uses, beyond a flexi desk address	PPT; QFZP adequate substance
Money	A UAE bank account that receives the Indian income and is run from the UAE	Beneficial ownership; FTA bank statement requirement
Discretion	No duty in contract or practice to pass dividends or royalties straight on	Beneficial ownership in Articles 10, 11 and 12
Accounts	Audited financial statements each year	FTA TRC requirement; QFZP conditions
Commercial reasons	A dated note of why the group used the UAE, such as a regional headquarters, customers or financing	PPT

We see two weak spots often. One is a UAE company whose only director is an Indian resident promoter. The other is a board that signs in India and couriers papers to Dubai. Both put Article 4(1)(b) and section 6(10) at risk at once.

Does a UAE company have to file an Indian tax return?

Yes, whenever it takes a treaty rate below the domestic rate. Section 207(8) of the Income Tax Act, 2025 excuses a foreign company only on two conditions. Its Indian income must consist of section 207 items, and tax must be deducted at the section 207 rate or more. A 10 percent treaty rate fails the second condition.

So a UAE parent paid a 10 percent dividend files an Indian return for that tax year. It needs a PAN, and section 263 sets the due date for companies. The return is also where it recovers tax deducted at the domestic rate before its TRC arrived.

Capital gains and PE profits also need a return. On our reading, section 207(8) covers dividends, interest, royalties and technical fees, not capital gains. We file the parent's return on the same engagement as the Form 146, so the Form 131 credit matches.

What changed in 2026

The treaty text did not change in 2026. The treaty page on incometaxindia.gov.in lists no notification after No. 29/2013, when we checked it on 2 Oct 2026. The Indian law around it changed, and so did UAE substance planning.

Item	Until 31 Mar 2026	From 1 Apr 2026	Instrument
Treaty relief and the more beneficial rule	Section 90(1) and 90(2)	Section 159(4)	Income Tax Act, 2025
GAAR override of treaties	Section 90(2A)	Section 159(6)	Income Tax Act, 2025
Tax residency certificate and other documents	Section 90(4) and 90(5)	Section 159(8)(a) and 159(8)(b)	Income Tax Act, 2025
Treaty information form	Form 10F, rule 21AB	Form 41, rule 75	Income Tax Rules, 2026
Withholding on payments to non residents	Section 195	Section 393(2), Table serial 17	Income Tax Act, 2025
Rates on dividends, interest, royalties and technical fees	Section 115A	Section 207	Income Tax Act, 2025
Return filing exemption	Section 115A(5)	Section 207(8)	Income Tax Act, 2025
Remittance, statement and certificate forms	Forms 15CA, 15CB, 27Q and 16A	Forms 145, 146, 144 and 131	Income Tax Rules, 2026
GAAR carve out for investments made before 1 Apr 2017	Rule 10U(1)(d), read with rule 10U(2)	Rule 128(2) as substituted; rule 10U also amended	Notification Nos. 54/2026 and 55/2026, 31 Mar 2026
Buy back by an Indian company from a UAE parent	Deemed dividend from 1 Oct 2024, so Article 10 at 10%	Capital gain, so Article 13(4) with no cap, on our reading	Finance Act, 2026
Tiger Global, a Mauritius treaty case on a tax residency certificate	Delhi High Court judgment stood until 15 Jan 2026	Set aside; the Supreme Court allowed the revenue's appeals on 15 Jan 2026	Supreme Court, 2026 INSC 60

Board packs, Forms 146 and bank letters should now cite sections 159 and 393, not sections 90 and 195. The other changes are mapped in our note on the Income Tax Act, 2025.

Worked example

A UAE parent receiving a dividend, a royalty and interest

GulfCo LLC is a mainland Dubai company, incorporated in 2019 and run by a board that meets in Dubai. It owns 100 percent of IndiaCo Private Limited. A nominee holds one share for GulfCo. In tax year 2026-27 IndiaCo pays GulfCo three amounts:

1. A royalty of INR 1,00,00,000 for the use of GulfCo's trade mark, booked on 31 Oct 2026.
2. An interim dividend of INR 4,00,00,000, declared on 10 Nov 2026 under section 123(3) of the Companies Act, 2013.
3. Interest of INR 50,00,000 on a rupee loan from GulfCo, credited on 31 Dec 2026.

GulfCo holds FTA certificates covering both its 2026 and 2027 financial years. It filed Form 41 for tax year 2026-27 in May 2026. It has a PAN and has given beneficial ownership and no PE declarations. Its total from IndiaCo in the year is INR 5,50,00,000, in the 2 percent surcharge slab.

Line (INR)	Dividend, treaty	Dividend, domestic	Royalty, treaty	Royalty, domestic	Interest, treaty	Interest, domestic
Gross amount	4,00,00,000	4,00,00,000	1,00,00,000	1,00,00,000	50,00,000	50,00,000
Base rate	10%	20%	10%	20%	12.5%	35%
Base tax	40,00,000	80,00,000	10,00,000	20,00,000	6,25,000	17,50,000
Surcharge at 2% of base tax	Nil	1,60,000	Nil	40,000	Nil	35,000
Health and Education Cess at 4%	Nil	3,26,400	Nil	81,600	Nil	71,400
Tax withheld	40,00,000	84,86,400	10,00,000	21,21,600	6,25,000	18,56,400
Net amount remitted	3,60,00,000	3,15,13,600	90,00,000	78,78,400	43,75,000	31,43,600

On the treaty route IndiaCo withholds INR 56,25,000 in total, against INR 1,24,64,400 on the domestic route. GulfCo receives INR 4,93,75,000 instead of INR 4,25,35,600, a difference of INR 68,39,400.

In the UAE, on our reading, the dividend is exempt under Article 23 as a participation. The royalty and interest are taxable at 9 percent. GulfCo claims a foreign tax credit under Article 47 for the INR 16,25,000 withheld on them. The credit is capped at the UAE tax on that income.

Date	Step	Rule
31 Oct 2026	Book the royalty and deduct INR 10,00,000	Section 393(2), serial 17
Before the royalty leaves India	Obtain Form 146 citing Article 12; file Form 145, Part C	Rule 220
7 Nov 2026	Deposit the tax on the royalty	Rule 218(2)
10 Nov 2026	Declare the dividend, book it and deduct INR 40,00,000	Companies Act s.123(3); section 393(2)
By 15 Nov 2026	Deposit the dividend in a separate bank account	Companies Act s.123(4)
7 Dec 2026	Deposit the tax on the dividend	Rule 218(2)
By 10 Dec 2026	Pay the dividend to GulfCo's bank account in the UAE, after Forms 146 and 145	Companies Act s.127; rule 220
31 Dec 2026	Credit the interest and deduct INR 6,25,000	Section 393(2), serial 17
7 Jan 2027	Deposit the tax on the interest	Rule 218(2)
By 31 Jan 2027	File Form 144 for October to December 2026 at the treaty rates	Rule 219
By 15 Feb 2027	Issue Form 131 for all three payments	Rule 215
Section 263 due date	GulfCo files its Indian return for tax year 2026-27	Section 207(8)

IndiaCo also pays IGST on the imported royalty under reverse charge and usually claims it back as input tax credit. It reports all three payments in its transfer pricing report in Form 48 under section 172. Our TP documentation guide covers the file behind it.

A management fee and a service PE

Suppose GulfCo also charges IndiaCo INR 1,20,00,000 for regional management services in the same year. The treaty has no article on technical fees. So the fee is GulfCo's business profit under Article 7. IndiaCo deducts nothing and files Form 145 in Part D, backed by a written treaty analysis.

Now suppose GulfCo sent two consultants to roll out a system at IndiaCo's plant, on one project. They worked in India from 1 May 2026 to 15 Mar 2027, about 10.5 months. That crosses the 9 month limit within a twelve month period in Article 5(2)(i). GulfCo has a service PE.

Assume INR 30,00,000 of profit is attributable to the PE. India taxes it at 35 percent, and the income is below INR 1,00,00,000, so no surcharge applies. Tax is INR 10,50,000 plus 4 percent cess of INR 42,000, a total of INR 10,92,000. GulfCo files an Indian return and keeps PE accounts. The project calendar decided this result, not the invoice label.

A later sale of IndiaCo shares

In 2027 GulfCo sells its IndiaCo shares, subscribed in 2015, to an Indian buyer. The long term gain is INR 3,00,00,000. A Singapore or Mauritius seller might argue for grandfathering on shares bought before 2017. The UAE treaty has no such clause, so India taxes the whole gain under Article 13(4).

Line (INR)	Amount
Long term gain on unlisted shares	3,00,00,000
Tax at 12.5% under section 197	37,50,000
Surcharge at 2% of tax	75,000
Health and Education Cess at 4%	1,53,000
Total Indian tax, effective 13.26%	39,78,000

The buyer withholds INR 39,78,000 under section 393(2), serial 17. The 2 percent slab is an assumption; the buyer applies the slab for the actual payment. In the UAE, the gain may qualify for the participation exemption under Article 23, on our reading.

Common mistakes

1. Treating every UAE company as a treaty resident. Fix: test both limbs of Article 4(1)(b) before the first payment.
2. Applying a 10 percent technical fee rate from another treaty. Fix: classify the fee under Article 7, Article 12 or Article 22. A pure service fee bears no Indian tax without a PE.
3. Missing the royalty in an equipment lease. Fix: treat rentals for industrial, commercial or scientific equipment as royalties at 10 percent.
4. Quoting Article 29 as the anti abuse test. Fix: apply the MLI principal purpose test, which replaced Article 29 from 1 Apr 2020.
5. Assuming pre 2017 holdings are exempt from capital gains tax. Fix: apply Article 13(4). The UAE treaty has no grandfathering.
6. Paying before the UAE company can get a TRC. Fix: check that the company is at least one year old.
7. Holding one TRC for a calendar year. Fix: hold certificates for both UAE financial years that overlap India's April to March tax year.
8. Adding surcharge and cess to the treaty rate. Fix: apply the treaty rate flat and cite the article in Form 146.
9. Letting Indian promoters run the UAE company from India. Fix: hold board meetings in the UAE and minute key decisions there.
10. Citing sections 90 and 195 in a 2026 Form 146. Fix: cite sections 159, 207 and 393(2), serial 17.
11. Telling the parent the treaty rate ends its Indian filings. Fix: plan a PAN and an Indian return under section 207(8).

Checklist

1. Confirm the UAE company is incorporated in the UAE and managed and controlled wholly there.
2. Confirm it has existed for at least one year, then obtain an FTA TRC covering each payment date.
3. File Form 41 once for the tax year before the first payment.
4. Obtain a PAN, or collect the six rule 217 details.
5. Classify each payment as dividend, interest, royalty, business profit, other income or capital gain.
6. Test equipment rentals and know how payments against the royalty definition in Article 12(3).
7. Count consultant days in India by project against the 9 month test in Article 5(2)(i).
8. Add up the year's payments to fix the domestic surcharge slab.
9. Collect beneficial ownership and no PE declarations.
10. Review the substance file against the PPT, GAAR and section 6(10).
11. Deduct tax at the earlier of credit and payment, at the flat treaty rate.
12. Obtain Form 146 and file Form 145 before each remittance.
13. Deposit the tax by the 7th of the next month, file Form 144 and issue Form 131.
14. Check the UAE corporate tax result with a UAE adviser, including QFZP status and the participation exemption.
15. Remind the UAE company to file its Indian return.

To have us review a UAE payment, loan or exit before it happens, send the agreement and the shareholding through our contact page.

Frequently Asked Questions

What is the dividend tax rate under the India UAE DTAA?+

10 percent. Article 10(2) caps Indian tax on dividends at 10 percent of the gross amount where the UAE recipient is the beneficial owner. There is no minimum holding. The domestic rate under section 207(1) of the Income Tax Act, 2025 is 20 percent plus surcharge and cess. The UAE company needs a TRC and Form 41.

What is the TDS rate on interest paid to a UAE company?+

Article 11(2) caps it at 12.5 percent. The cap falls to 5 percent for a loan granted by a bank or similar financial institution. Domestic law charges 20 percent on foreign currency loans and 35 percent on rupee loans. So a rupee loan from a UAE parent bears 12.5 percent with a TRC and Form 41.

Does the India UAE DTAA have a fees for technical services clause?+

No. Article 12 covers royalties only. A technical, managerial or consultancy fee paid to a UAE company is business profit under Article 7. India taxes it only through a PE in India. Know how and secret processes can still fall in the royalty definition and bear 10 percent under Article 12.

Is a UAE free zone company a resident under the treaty?+

Yes, if it is incorporated in the UAE and managed and controlled wholly there, as Article 4(1)(b) requires. The treaty does not distinguish free zone and mainland companies. UAE law treats a free zone person as a UAE resident. The principal purpose test and GAAR still apply to each arrangement.

Does a 0 percent UAE tax rate block treaty benefits in India?+

Not under the residence article, on our reading. The UAE limb of Article 4(1)(b) asks about incorporation and management and control, not liability to tax. A 0 percent rate can still feature in a principal purpose test review. Keep a dated note of the commercial reasons for using the UAE company.

How long is a UAE tax residency certificate valid?+

The FTA says a TRC "is valid for one year from the beginning of the financial year selected by the applicant". India's tax year runs April to March. A UAE company with a calendar financial year therefore needs two certificates to cover all payments in one Indian tax year. Form 41 is still filed once per tax year.

Can a newly formed UAE company get a TRC?+

Not at once. The FTA service page says a legal person "must have been established in the UAE for at least one year". It also asks for audited accounts and a six month bank statement. Until then, the Indian payer deducts at the domestic rate. The UAE company can claim the excess in its Indian return only if it later proves residence.

Does India tax capital gains on Indian shares sold by a UAE company?+

Yes. Article 13(4), added by the 2007 protocol, lets India tax gains on shares of an Indian company. There is no cap and no grandfathering for older holdings. Long term gains on unlisted shares bear 12.5 percent under section 197, plus surcharge and cess. The buyer withholds under section 393(2).

Does Article 29 of the India UAE treaty still apply?+

No. The MLI synthesised text states that paragraph 1 of Article 7 of the MLI replaces Article 29 of the Agreement. For Indian taxes the principal purpose test applies from 1 Apr 2020. It asks whether obtaining a benefit was one of the principal purposes of any arrangement or transaction. The old Article 29 looked only at why the entity was created.

Does a UAE parent's staff visiting India create a PE?+

Only past the treaty thresholds. Article 5(2)(i) creates a service PE after 9 months on the same or a connected project within any twelve month period. The treaty has no shorter limit for related enterprises. A fixed place used as the parent's own, or a dependent agent concluding contracts, also creates a PE.

Is an equipment lease payment to a UAE company a royalty?+

Yes, under this treaty. Article 12(3) includes payments for "the use of, or the right to use, industrial, commercial or scientific equipment". So lease rentals to a UAE company bear Indian tax capped at 10 percent. The Indian lessee deducts under section 393(2) at that rate once it holds the TRC and Form 41.

Is a dividend from an Indian subsidiary taxed again in the UAE?+

Usually not, on our reading. Article 23 of Federal Decree Law No. 47 of 2022 exempts income from a participation of at least 5 percent held, or intended to be held, for 12 months. The subsidiary must be taxed at a rate of at least 9 percent. An Indian company paying 22 percent under section 200 clears that test. Confirm the other conditions with a UAE adviser.

Does the UAE withhold tax on dividends paid to an Indian parent?+

No. The UAE Ministry of Finance says withholding tax on UAE source income of non residents is at 0 percent. Article 10 of the treaty would allow the UAE up to 10 percent, but UAE law charges nothing. The Indian parent pays Indian tax on the dividend and claims no foreign tax credit, since none was paid.

Do surcharge and cess apply on top of the treaty rate?+

We do not add them. Tribunal rulings treat the treaty cap as the full Indian tax, including surcharge and cess. No CBDT circular settles the point. So we apply 10 percent flat on a qualifying dividend and state the article in Form 146. A payer adding them would deduct 10.608 percent in the 2 percent slab.

Which forms replaced Form 10F, 15CA and 15CB?+

From 1 Apr 2026, Form 41 replaced Form 10F under rule 75 of the Income Tax Rules, 2026. Forms 145 and 146 replaced Forms 15CA and 15CB under rule 220. Form 144 replaced Form 27Q, and Form 131 replaced Form 16A. An Indian resident now applies for a residence certificate in Form 42 and receives it in Form 43.

How long does a UAE company have to start a mutual agreement procedure?+

Three years. Article 27 originally allowed two years from the notice of the action. The MLI changed that to three years "from the first notification of the action". The Indian application form is Form 55, and a bilateral advance pricing agreement starts with Form 51.

Sources

• Income Tax Department, India UAE DTAA with amendments (GSR 710(E), 18 Nov 1993; S.O. 2001(E), 28 Nov 2007; Notification No. 29/2013, 12 Apr 2013), read 2 Oct 2026, https://www.incometaxindia.gov.in/w/uae-comprehensive-agreements-1
• Income Tax Department, Synthesised text of the India UAE DTAA as modified by the MLI, read 2 Oct 2026, https://www.incometaxindia.gov.in/w/uae-synthesised-text-1
• Central Board of Direct Taxes, Circular No. 01/2025, Guidance for application of the Principal Purpose Test under India's DTAAs, 21 Jan 2025, https://www.incometaxindia.gov.in/documents/d/guest/circular-1-2025-pdf
• Central Board of Direct Taxes, Notification No. 54/2026, Income Tax (Tenth Amendment) Rules, 2026 (rule 10U), G.S.R. 240(E), 31 Mar 2026, https://www.incometaxindia.gov.in/documents/d/guest/notification-no-54-2026-pdf
• Central Board of Direct Taxes, Notification No. 55/2026, Income Tax (Amendment) Rules, 2026 (rule 128), G.S.R. 241(E), 31 Mar 2026, https://www.incometaxindia.gov.in/documents/d/guest/notification-no-55-2026-1-pdf
• Supreme Court of India, Authority for Advance Rulings (Income Tax) v. Tiger Global International II Holdings, 2026 INSC 60, 15 Jan 2026, https://api.sci.gov.in/supremecourt/2025/1251/1251_2025_7_1501_67552_Judgement_15-Jan-2026.pdf
• Income Tax Department, Section 6 of the Income Tax Act, 2025 (residence; sub section (10)), https://www.incometaxindia.gov.in/w/section-6-1
• Income Tax Department, Section 159 of the Income Tax Act, 2025 (double taxation relief), read 2 Oct 2026, https://www.incometaxindia.gov.in/w/section-159-89
• Income Tax Department, Section 207 of the Income Tax Act, 2025 (sub sections (1), (2) and (8)), read 2 Oct 2026, https://www.incometaxindia.gov.in/w/section-207-78
• Income Tax Department, Section 197 of the Income Tax Act, 2025 (long term capital gains), https://www.incometaxindia.gov.in/w/section-197-78
• Income Tax Department, Section 393 of the Income Tax Act, 2025 (tax deducted at source), https://www.incometaxindia.gov.in/w/section-393-6
• Income Tax Department, Section 397 of the Income Tax Act, 2025 (PAN and information on payments to non residents), https://www.incometaxindia.gov.in/w/section-397-6
• Income Tax Department, Rules 215, 217, 218, 219 and 220 of the Income Tax Rules, 2026, https://www.incometaxindia.gov.in/w/rule-215-1, https://www.incometaxindia.gov.in/w/rule-217-1, https://www.incometaxindia.gov.in/w/rule-218-1, https://www.incometaxindia.gov.in/w/rule-219-1, https://www.incometaxindia.gov.in/w/rule-220-1
• Income Tax Department, Guidance note on Form 41, https://www.incometaxindia.gov.in/documents/d/guest/fn-41
• Income Tax Department, FAQs and Guidance Notes on Forms as per Income Tax Rules, 2026 (form map), https://www.incometaxindia.gov.in/faqs-and-guidance-notes-on-forms-as-per-income-tax-rules-2026
• Ministry of Finance UAE, Corporate Tax in the UAE, read 2 Oct 2026, https://mof.gov.ae/en/public-finance/tax/corporate-tax-in-the-uae/
• Ministry of Finance UAE, Federal Decree Law No. 47 of 2022 and its amendments (unofficial English translation, January 2026), https://mof.gov.ae/wp-content/uploads/2026/01/Federal-Decree-Law-No.-47-of-2022-and-its-amendments-en-v13.1.26.pdf
• UAE Government portal, Corporate tax (CT), read 2 Oct 2026, https://u.ae/en/information-and-services/finance-and-investment/taxation/corporate-tax
• Ministry of Finance UAE, Top up Tax (Domestic Minimum Top up Tax), read 2 Oct 2026, https://mof.gov.ae/en/public-finance/tax/uae-domestic-minimum-top-up-tax/
• Ministry of Finance UAE, Pillar Two guidance paper, March 2024, https://mof.gov.ae/wp-content/uploads/2024/03/Pillar-2-Guidance-document.pdf
• Ministry of Finance UAE, Cabinet Decision No. 100 of 2023 on Determining Qualifying Income for the Qualifying Free Zone Person, https://mof.gov.ae/wp-content/uploads/2023/11/Cabinet-Decision-No.-100-of-2023-on-Determining-Qualifying-Income-for-the-Qualifying-Free-Zone-Person.pdf
• Ministry of Finance UAE, Ministerial Decision No. 229 of 2025 Regarding Qualifying Activities and Excluded Activities, 28 Aug 2025, https://mof.gov.ae/wp-content/uploads/2025/09/EN-Ministerial-Decision-No.-229-of-2025-Regarding-Qualifying-Activities-and-Excluded-Activities.pdf
• Ministry of Finance UAE, Amendment to Cabinet Decision on Economic Substance Requirements, 14 Oct 2024, https://mof.gov.ae/en/news/ministry-of-finance-announces-amendment-to-cabinet-decision-on-economic-substance-requirements/
• Ministry of Finance UAE, Ministerial Decision No. 247 of 2023 on the Issuance of Tax Residency Certificate for the Purposes of International Agreements, 16 Oct 2023, https://mof.gov.ae/wp-content/uploads/2023/10/Ministerial-Decision-No247-of-2023-on-the-Issuance-of-Tax-Residency-Certificate-for-the-Purposes-of-International-Agreements.pdf
• Federal Tax Authority, Issuance of Tax Residency Certificate (TRC), read 2 Oct 2026, https://tax.gov.ae/en/services/issuance.of.tax.residency.certificate.aspx
• Federal Tax Authority, Corporate Tax Guide on Free Zone Persons (news release), 26 May 2024, https://tax.gov.ae/en/media.centre/news/federal.tax.authority.issues.corporate.tax.guide.on.free.zone.persons.aspx