International Taxation
International Taxation Services in the UAE
Corporate tax has turned the UAE from a tax-free hub into a jurisdiction with a treaty network to use, a residence test to meet and a set of anti-avoidance rules to respect. For UAE companies selling or investing abroad, and for foreign groups with operations, staff or customers in the UAE, the tax outcome now depends on how the cross-border arrangements are structured and documented.
Reflechir advises on the interaction between UAE corporate tax and the tax systems of the countries you trade with, so that profits are taxed once, in the right place, and the position can be defended to the FTA and the foreign authority alike.
Where international tax questions arise
- Selling or providing services abroad: whether your UAE company creates a taxable presence (permanent establishment) in the customer's country, and how foreign withholding tax on your invoices can be relieved or credited.
- Foreign companies operating in the UAE: whether staff, agents, warehouses or projects in the UAE create a permanent establishment that brings the foreign company into UAE corporate tax.
- Holding structures and dividends: applying the UAE participation exemption to foreign subsidiaries, the foreign permanent establishment exemption, and treaty relief on dividends, interest and royalties flowing in and out.
- Group financing and intra-group services: interest deductibility limits, transfer pricing on management fees and royalties, and the arm's length documentation both countries expect.
- Individuals and family offices: tax residence of owners who split time between countries, and the effect of UAE residence on foreign tax obligations.
- Large multinationals: the UAE's Domestic Minimum Top-up Tax under Pillar Two for groups above the revenue threshold, and Country-by-Country Reporting obligations.
What the service covers
- Treaty analysis: confirming which of the UAE's double tax treaties applies, what relief it provides, and the residence, beneficial ownership and substance conditions that must be met to claim it.
- Permanent establishment reviews: assessing existing arrangements for PE risk in the UAE and abroad, and restructuring contracts, staffing and decision-making where needed.
- Withholding tax and foreign tax credits: obtaining treaty rates at source, claiming credits for foreign tax under the UAE corporate tax law, and evidencing them in the return.
- Structuring advice: holding, financing and operating structures for outbound investment from the UAE and inbound investment into it, including free zone and Qualifying Free Zone Person considerations.
- Tax residency certificates: preparing and filing TRC applications with the FTA so treaty benefits can be claimed.
- Coordination with foreign advisors: working with the counterpart accountant or lawyer in the other country so the position is consistent on both sides.
How the engagement works
International tax work is scoped as a specific question or transaction, with a fixed fee for the advice and any filings that follow. Reflechir reviews the contracts, group structure and financial flows, sets out the UAE and foreign tax treatment in a written memorandum with the options and their consequences, and then implements the agreed option: restructuring, documentation, TRC applications, treaty claims and corporate tax return disclosures. For groups with ongoing cross-border activity, the advice is refreshed annually as part of the corporate tax return cycle.
Why Reflechir
- Corporate tax and international tax together: the cross-border position is worked into the UAE corporate tax computation and transfer pricing file, not advised in isolation.
- Practical, written answers: a memorandum you can give to your board, your bank or your foreign advisor, with the law cited.
- Experience with UAE free zones and holding companies: the structures most UAE-based owners actually use.
If your business earns income abroad, pays foreign suppliers, or belongs to a foreign group, contact Reflechir Consultancy for a review of your international tax position.