The UAE and France tax treaty.
What the treaty means if you or your company has income, profits or residence in both countries.
Position as at 12 November 2026
Applies from: Withholding taxes: payments from 1 July 1990. Other income tax: income of calendar year 1990.
Entry into force: In force since 1 July 1990 (French tax administration and the UAE's own MLI filing). UAE Ministry of Finance sources also give 8 November 1989 (dashboard) and 8 November 1994 (2023 table).
Signed: 19 July 1989
Withholding rates
What tax is taken at source.
Last checked 12 November 2026. Sources
| Payment | Treaty cap | Domestic rate without treaty | Conditions and evidence |
|---|---|---|---|
| DividendsArt. 8 | 0% | French rate without the treaty: 25% for companies (12.8% for individuals); 75% if paid to a non-cooperative state | Dividends paid by a French company to a UAE resident who beneficially owns them are taxed only in the UAE. France cannot tax them. No shareholding condition. 5 of 5 official sourcesArt. 8
|
| InterestArt. 9 | 0% | French rate without the treaty: generally 0% for non-residents (75% if paid to a non-cooperative state) | Interest paid from France to a UAE resident who beneficially owns it is taxed only in the UAE. 3 of 3 official sourcesArt. 9
|
| RoyaltiesArt. 10 | 0% | French rate without the treaty: 25% (15% for certain payments under art 182 B I d); 75% if paid to a non-cooperative state | Royalties paid from France to a UAE resident who beneficially owns them are taxed only in the UAE, including payments for using equipment. 3 of 3 official sourcesArt. 10
|
The treaty can reduce the rate to the lower of the two, usually only once you claim it with a UAE tax residence certificate. The UAE charges 0% on these payments. Position as at 12 November 2026.
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Sources for the France treaty
Sources differApplies from: Withholding taxes: payments from 1 July 1990. Other income tax: income of calendar year 1990.
Entry into force: In force since 1 July 1990 (French tax administration and the UAE's own MLI filing). UAE Ministry of Finance sources also give 8 November 1989 (dashboard) and 8 November 1994 (2023 table).
Convention entre le Gouvernement de la République française et le Gouvernement des Émirats arabes unis en vue d'éviter les doubles impositions (ensemble un échange de lettres)
Official source
Last checked 12 November 2026
Official sourceUAE Ministry of Finance
Last checked 12 November 2026
UAE Ministry of FinanceOfficial source
Last checked 12 November 2026
Official sourceOECD MLI filing
Last checked 12 November 2026
OECD MLI filingUAE Ministry of Finance, treaty table (2023)
Last checked 12 November 2026
UAE Ministry of Finance, treaty table (2023)UAE Ministry of Finance, treaty dashboard
Last checked 12 November 2026
UAE Ministry of Finance, treaty dashboardWhat changed on this page
No checked change events are available in this dataset.
Position as at 12 November 2026. How we check
Moving from France
Where you are resident for tax.
UAE resident: "toute personne qui est domiciliée, établie, ou a son siège de direction dans les Emirats arabes unis" (Art 4(1)(b)). Art 18(5) lets a state refuse relief to its domestic resident treated as UAE resident via the nationality step. Art 19(2) override: where a UAE resident or established person is fiscally domiciled in France under French law, or is a subsidiary more than 50% controlled by a company managed in France, France may tax its income "nonobstant toute autre disposition de la présente Convention", with a credit for UAE tax; not applicable to individuals who are UAE citizens.
Running a company
When a France business is taxed in the UAE.
Siège de direction effective (Art 4(3)).
Selling assets
Selling shares or property.
May be taxed where the property is (Art 11(1)(a)). Shares in companies whose assets are more than 80% immovable property may be taxed in the situs state where its law taxes such gains as gains on immovable property; property used in the company's own industrial, commercial, agricultural or professional activity is left out (Art 11(1)(b)). Substantial participation over 25% taxed in the company's state (Art 11(3)).
Pensions
Pensions and retirement income.
Private pensions: residence state only (Art 14(1)); social security pensions may be taxed in the paying state (Art 14(2)). Government-service pensions: only in the paying state (Art 15(2)); Art 15(3) returns pensions for services in a state's commercial activity to the ordinary rules.
Treaty updates
How the multilateral instrument changes this treaty.
Both countries list this treaty under the MLI. A principal purpose test now applies to all treaty benefits.
Checked by PBF against official sources. Position as at 12 November 2026. How we check
PBF UAE Tax Hub. General information, not advice.