{"version":2,"checked_at":"2026-11-11","rows":[{"payment":"dividends","home_rate":"0% (UAE Corporate Tax Law Art 45(1): State Sourced Income of a Non-Resident not attributable to a PE or nexus is taxed at 0% withholding tax)","partner_rate":"No WHT on dividends or interest. Royalties paid to non-residents: deemed assessable profits of 30% of the sum, or 100% if received from an associate (unless the Commissioner is satisfied no Hong Kong business person ever owned the property), taxed at profits tax rates: 16.5% standard for corporations (8.25% on the first HK$2 million if two-tier rates apply). Effective about 4.95% (30% x 16.5%) for a corporation.","treaty_rate":"0% for the other party's government bodies and wholly owned entities; 5% otherwise (Art 10(2)). No participation threshold.","conditions":"","position_as_at":"2026-11-11","source":"https://mof.gov.ae/wp-content/uploads/2023/08/Avoidance-of-Double-Taxation-Agreements1.pdf"},{"payment":"interest","home_rate":"0% (UAE Corporate Tax Law Art 45(1): State Sourced Income of a Non-Resident not attributable to a PE or nexus is taxed at 0% withholding tax)","partner_rate":"No WHT on dividends or interest. Royalties paid to non-residents: deemed assessable profits of 30% of the sum, or 100% if received from an associate (unless the Commissioner is satisfied no Hong Kong business person ever owned the property), taxed at profits tax rates: 16.5% standard for corporations (8.25% on the first HK$2 million if two-tier rates apply). Effective about 4.95% (30% x 16.5%) for a corporation.","treaty_rate":"5% (Art 11(2)); listed government bodies exempt (Art 11(3)).","conditions":"","position_as_at":"2026-11-11","source":"https://mof.gov.ae/wp-content/uploads/2023/08/Avoidance-of-Double-Taxation-Agreements1.pdf"},{"payment":"royalties","home_rate":"0% (UAE Corporate Tax Law Art 45(1): State Sourced Income of a Non-Resident not attributable to a PE or nexus is taxed at 0% withholding tax)","partner_rate":"No WHT on dividends or interest. Royalties paid to non-residents: deemed assessable profits of 30% of the sum, or 100% if received from an associate (unless the Commissioner is satisfied no Hong Kong business person ever owned the property), taxed at profits tax rates: 16.5% standard for corporations (8.25% on the first HK$2 million if two-tier rates apply). Effective about 4.95% (30% x 16.5%) for a corporation.","treaty_rate":"5% (Art 12(2)); definition includes equipment.","conditions":"","position_as_at":"2026-11-11","source":"https://mof.gov.ae/wp-content/uploads/2023/08/Avoidance-of-Double-Taxation-Agreements1.pdf"}]}