United Arab Emirates : tax treaty relief on international investment

To date, the United Arab Emirates has concluded 47 comprehensive tax treaties, over two thirds of which are in force. This is an extensive treaty network for a jurisdiction most of whose residents do not currently pay any income tax. This article addresses some of the issues faced by UAE individuals, companies and government institutions when trying to qualify for treaty relief on income generated on their outbound investments. After discussing the sources and interpretation of UAE treaty law, the article examines the scope of bilateral treaties with regard to taxes, period in time, territory and persons. To complete the analysis, the article considers some of the anti-abuse rules in the UAE's tax treaties and in the source country's domestic law.