Tax·Luxury

Part II · Jurisdictions · No. 16

United Arab Emirates

A federation of seven emirates with no individual income tax. The 2022 corporate-tax law introduced a 9% federal corporate income tax, preserving free-zone qualifying-income exemptions. Dubai operates one of the world's largest gold trading centers and is a major destination for HNW migration.

Why this jurisdiction matters

The UAE has emerged as a major HNW migration destination since 2020. Combination of no personal income tax, Golden Visa long-term residency, modern infrastructure, and free-zone business framework appeals to high-net-worth individuals. The 2022 Corporate Tax Law (Federal Decree-Law No. 47) introduced a 9% federal corporate tax effective June 1, 2023, while preserving free-zone qualifying income at 0%.

The relevant tax regime

Registration or residency mechanics

Residency via employment visa, freelance visa, or Golden Visa (long-term residency for investors, entrepreneurs, specialized talent, students, retirees). Real-estate-based Golden Visa requires minimum property value (AED 2 million). Pillar Two GloBE rules apply to in-scope multinational groups.

Reporting and disclosure

CRS participant (since 2018). FATCA Model 1B IGA with the U.S. Beneficial-ownership registration through Ministry of Economy. AML compliance strengthened post-FATF gray-listing and subsequent removal.

The substance question

UAE tax residency for tax treaty purposes generally requires substantive residency. Cabinet Decision No. 85 of 2022 sets out tax-residence tests including 90- and 183-day presence requirements. Substance for corporate-tax exemption in free zones requires qualifying income from qualifying activities.

Recent changes

9% corporate tax (effective 2023). FATF gray list (2022) and removal (2024). Pillar Two implementation for large multinationals. Continued AML reform.

Common asset classes parked here

Primary Sources

  1. Federal Decree-Law No. 47 of 2022 on Taxation of Corporations and Businesses.
  2. Federal Decree-Law No. 8 of 2017 on Value Added Tax.
  3. Federal Decree-Law No. 7 of 2017 on Excise Tax.
  4. Cabinet Decision No. 85 of 2022 (tax-residence determination).
  5. Federal Tax Authority — tax.gov.ae.
  6. UAE Federal Decree-Law No. 19 of 2018 on Foreign Direct Investment.

Reviewed May 2026