{"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":"Dividends 15% (Wet DB 1965 art 5). Conditional WHT (Wet bronbelasting 2021) at 25.8% on interest, royalties and dividends to related entities in low-tax jurisdictions and in certain abuse cases. The UAE is not on the 2026 low-tax list, so only the abuse limb could apply to UAE recipients; treaty limits then apply.","treaty_rate":"5% where the beneficial owner is a company whose capital is wholly or partly divided into shares and which holds directly at least 10% of the capital; 10% otherwise (Art 10(2)). Exempt for the specified public bodies and pension funds listed in Art 10(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":"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":"Dividends 15% (Wet DB 1965 art 5). Conditional WHT (Wet bronbelasting 2021) at 25.8% on interest, royalties and dividends to related entities in low-tax jurisdictions and in certain abuse cases. The UAE is not on the 2026 low-tax list, so only the abuse limb could apply to UAE recipients; treaty limits then apply.","treaty_rate":"0%: taxable only in the residence state (Art 11(1)).","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":"Dividends 15% (Wet DB 1965 art 5). Conditional WHT (Wet bronbelasting 2021) at 25.8% on interest, royalties and dividends to related entities in low-tax jurisdictions and in certain abuse cases. The UAE is not on the 2026 low-tax list, so only the abuse limb could apply to UAE recipients; treaty limits then apply.","treaty_rate":"0%: taxable only in the residence state (Art 12(1)).","conditions":"","position_as_at":"2026-11-11","source":"https://mof.gov.ae/wp-content/uploads/2023/08/Avoidance-of-Double-Taxation-Agreements1.pdf"}]}