{"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: no UK WHT on ordinary dividends (REIT PIDs 20%). Yearly interest: 20% (savings basic rate), ITA 2007 s 874. Royalties: 20% (basic rate), ITA 2007 s 906.","treaty_rate":"0% (exempt at source), Art 10(2)(a). 15% for dividends paid by a property investment vehicle out of exempt property income (Art 10(2)(b)); exempt again where the beneficial owner is a pension scheme. No participation threshold.","conditions":"All treaty rates assume the UAE recipient is the beneficial owner. They do not apply where the holding, debt claim or right is effectively connected with a PE or fixed base in the source state. Interest and royalty relief covers only the arm's-length amount where a special relationship inflates the payment.","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: no UK WHT on ordinary dividends (REIT PIDs 20%). Yearly interest: 20% (savings basic rate), ITA 2007 s 874. Royalties: 20% (basic rate), ITA 2007 s 906.","treaty_rate":"Taxable only in the residence state (exempt at source) where the UAE resident is the beneficial owner and either (a) it is within Art 11(3)(a): the state or its bodies, an individual, a listed company, a pension scheme, an unrelated financial institution, or a company whose structure the competent authority accepts was not set up mainly to obtain the treaty benefit; or (b) the interest is paid by a Contracting State, its political subdivisions, local governments, local authorities or statutory bodies (Art 11(3)(b)). Otherwise no treaty limit, so UK domestic WHT applies (20% on yearly interest within ITA 2007 s 874). HMRC summary: \"No relief (note 2)\".","conditions":"All treaty rates assume the UAE recipient is the beneficial owner. They do not apply where the holding, debt claim or right is effectively connected with a PE or fixed base in the source state. Interest and royalty relief covers only the arm's-length amount where a special relationship inflates the payment.","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: no UK WHT on ordinary dividends (REIT PIDs 20%). Yearly interest: 20% (savings basic rate), ITA 2007 s 874. Royalties: 20% (basic rate), ITA 2007 s 906.","treaty_rate":"0% (taxable only in residence state), Art 12(1).","conditions":"All treaty rates assume the UAE recipient is the beneficial owner. They do not apply where the holding, debt claim or right is effectively connected with a PE or fixed base in the source state. Interest and royalty relief covers only the arm's-length amount where a special relationship inflates the payment.","position_as_at":"2026-11-11","source":"https://mof.gov.ae/wp-content/uploads/2023/08/Avoidance-of-Double-Taxation-Agreements1.pdf"}]}