Treaty withNetherlands
The UAE and the Netherlands tax treaty.
What the treaty means if you or your company has income, profits or residence in both countries.
Position as at 11 November 2026
Applies from: Art 28(2): income taxes assessed periodically, tax years from 1 Jan 2011; all other cases, including dividend withholding tax, from 2 June 2010. There is no 2023 protocol. Tractatenblad 2023 no. 50 is the MLI synthesised text.
Entry into force: 2 June 2010
Signed: 8 May 2007
Withholding rates
What tax is taken at source.
Last checked 11 November 2026. Sources
| Payment | Treaty cap | Domestic rate without treaty | Conditions and evidence |
|---|---|---|---|
| DividendsArt. 10 | 5% / 10% | Netherlands rate without the treaty: 15% | 5% if a company owns at least 10% of the payer directly; otherwise 10%. 1 of 2 official sourcesArt. 10
|
| InterestArt. 11 | 0% | Netherlands rate without the treaty: 0% (25.8% conditional tax only in abuse cases) | Taxed only in the UAE; the Netherlands cannot tax it. 1 of 2 official sourcesArt. 11
|
| RoyaltiesArt. 12 | 0% | Netherlands rate without the treaty: 0% (25.8% conditional tax only in abuse cases) | Taxed only in the UAE; the Netherlands cannot tax it. 1 of 2 official sourcesArt. 12
|
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 11 November 2026.
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Sources for the Netherlands treaty
4 of 4 official sourcesApplies from: Art 28(2): income taxes assessed periodically, tax years from 1 Jan 2011; all other cases, including dividend withholding tax, from 2 June 2010. There is no 2023 protocol. Tractatenblad 2023 no. 50 is the MLI synthesised text.
Entry into force: 2 June 2010
Convention between the Kingdom of the Netherlands and the United Arab Emirates for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income (with Protocol)
wetten.overheid.nl treaty text, Art 28
Last checked 11 November 2026
wetten.overheid.nl treaty text, Art 28UAE MLI position, OECD
Last checked 11 November 2026
UAE MLI position, OECDUAE Ministry of Finance, treaty table (2023)
Last checked 11 November 2026
UAE Ministry of Finance, treaty table (2023)UAE Ministry of Finance, treaty dashboard
Last checked 11 November 2026
UAE Ministry of Finance, treaty dashboardWhat changed on this page
No checked change events are available in this dataset.
Position as at 11 November 2026. How we check
Moving from the Netherlands
Where you are resident for tax.
This treaty is narrower than some others for individuals.
UAE individual must be "a national of the United Arab Emirates" with substantial presence, permanent home or habitual abode, and closer ties to the UAE; UAE company: place of effective management in the UAE (Art 4(1)(b)). Expatriates in the UAE do not qualify.
Running a company
When a business in the Netherlands is taxed in the UAE.
Mutual agreement, having regard to place of effective management and incorporation (Art 4(4)).
Selling assets
Selling shares or property.
May be taxed where the property is (Art 13(1)). No land-rich shares clause. Protocol XI preserves the Dutch substantial-interest claim on emigrants.
Pensions
Pensions and retirement income.
Pensions and social security may be taxed in the source state (Art 17(1)-(2)); Protocol XII "derived from" test. Government-service pensions: may be taxed in the paying state, but only in the other state if the individual is a resident and national of it (Art 18(2)).
Treaty updates
How the multilateral instrument changes this treaty.
Covered tax agreement for both (NL 74, UAE 76). MLI in force NL 1 Jul 2019, UAE 1 Sep 2019; effect 1 Jan 2020 (WHT), periods from 1 Mar 2020 (other). Applied: preamble (Art 6), Art 7 PPT replacing Art 10(9), Art 5, Art 16, Art 17. MAP (Art 16) applies to cases presented on or after 1 Sep 2019.
Checked by PBF against official sources. Position as at 11 November 2026. How we check
PBF UAE Tax Hub. General information, not advice.