SolvedDT19752 | Double Taxation Relief Manual: United Arab Emirates: treaty summary
From HM Revenue & Customs · Double Taxation Relief Manual
The table summarises the provisions of the treaty as they relate to income beneficially owned by UK residents. The rate shown is the ‘treaty rate’ and does not reflect taxes chargeable under domestic law before relief is given under the provisions of the treaty. The ‘treaty rate’ is the maximum rate at which the UAE is permitted to tax income in the relevant categories under the treaty. Rates chargeable under domestic law may be higher or lower.
In all cases other conditions for relief (e.g. beneficial ownership) will have to be met before relief is due under the treaty. The text of the treaty itself should be consulted for the full details. The text of the treaty can be found on gov.uk.
| Subject | Comments | Article |
|---|---|---|
| Portfolio dividends | 0% | Article 10 |
| Dividends on direct investments | 0% | Article 10 |
| Conditions for lower rate on dividends on direct investments | Not applicable | Article 10 |
| Property income dividends (moveable or immoveable property) | 15% (note 1) | Article 10 |
| Interest | No relief (note 2) | Article 11 |
| Royalties | 0% | Article 12 |
| Government pensions | Taxable only in the UAE unless the individual is resident in, and a national of, the UK | Article 18 |
| Other pensions | Taxable only in the UK | Article 17 |
| Arbitration | No | Article 23 |
Note 1: property income dividends are taxable only in the UK if the beneficial owner is a pension scheme established in the UK.
Note 2: Interest is taxable only in the UK if at least one of the following conditions is met:
The interest is beneficially owned by:
the government of the UK, one of the UK’s political subdivisions, local governments, local authorities, the Bank of England, or a UK statutory body;
an individual;
a company in whose principal class of shares there is substantial and regular trading on a recognised stock exchange;
a pension scheme; or
a financial institution which is unrelated to and dealing wholly independently with the payer (the term “financial institution” here means a bank or other enterprise substantially deriving its profits by raising debt finance in the financial markets or by taking deposits at interest and using those funds in carrying on a business of providing finance);
a company other than a company mentioned under sub-paragraphs (iii), (iv) or (v) provided that the competent authority of the UAE determines that the establishment, acquisition or maintenance of the company does not have as its main purpose or one of its main purposes to secure the benefits of this Article; or
2. The interest is paid by the government of the UAE, one of its political subdivisions, local governments, local authorities or statutory bodies.