{"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":"Swiss withholding tax 35% on dividends and on bond and bank-deposit interest (VStG Art 13(1)(a)); customer-deposit interest not over CHF 200 a year is exempt (VStG Art 5(1)(c)); no WHT on ordinary loan interest or royalties.","treaty_rate":"5% where the beneficial owner is a company holding directly at least 10% of capital; 15% otherwise (Art 10(2)). Exempt for the state, central bank, pension funds and government investment bodies (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":"Swiss withholding tax 35% on dividends and on bond and bank-deposit interest (VStG Art 13(1)(a)); customer-deposit interest not over CHF 200 a year is exempt (VStG Art 5(1)(c)); no WHT on ordinary loan interest or royalties.","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":"Swiss withholding tax 35% on dividends and on bond and bank-deposit interest (VStG Art 13(1)(a)); customer-deposit interest not over CHF 200 a year is exempt (VStG Art 5(1)(c)); no WHT on ordinary loan interest or royalties.","treaty_rate":"0%: taxable only in the residence state (Art 12(1)); equipment rentals treated as business profits (Protocol para 4).","conditions":"","position_as_at":"2026-11-11","source":"https://mof.gov.ae/wp-content/uploads/2023/08/Avoidance-of-Double-Taxation-Agreements1.pdf"}]}
