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International Tax Advisory Services

Cross-border structuring advice for UAE businesses operating beyond the region.

UAE businesses with overseas customers, suppliers, subsidiaries or shareholders face a layer of tax questions that go beyond domestic Corporate Tax and VAT rules — from double tax treaties to permanent establishment risk in other jurisdictions. Corcess advises on how these cross-border rules interact with your UAE obligations, and coordinates with overseas advisors where local-country input is needed.

When International Tax Advice Is Needed

  • You have a subsidiary, branch or representative office outside the UAE
  • You're paying or receiving cross-border royalties, interest, dividends or service fees
  • You want to assess whether overseas activity creates a permanent establishment there
  • You're structuring a new international holding, financing or IP arrangement

Double Taxation Avoidance Agreements (DTAAs)

The UAE's extensive DTAA network can reduce or eliminate withholding tax on cross-border payments and prevent the same income being taxed twice. We assess which treaties apply to your structure and support the Tax Residency Certificate applications needed to claim treaty relief.

Permanent Establishment & Substance Risk

Activity carried out abroad — even by UAE-based staff — can create a taxable presence in another country if it crosses certain thresholds. We review your cross-border activities against common permanent establishment tests to flag exposure before it becomes a liability.

Cross-Border Structuring

  • Holding company and group structuring for outbound investment
  • Withholding tax planning on royalty, interest and dividend flows
  • Coordination with overseas tax advisors for local-country filings
  • Transfer pricing alignment across related entities in different jurisdictions

A Note on Economic Substance Regulations

The UAE's Economic Substance Regulations (ESR) reporting and notification requirements were formally abolished for financial years ending after 31 December 2022, under Cabinet Decision No. 98 of 2024 (amending Cabinet Decision No. 57 of 2020). Businesses no longer file separate ESR notifications or reports — but demonstrating genuine substance in the UAE remains directly relevant under the Corporate Tax regime, particularly for Qualifying Free Zone Person status and for supporting Tax Residency Certificate applications.

Relevant Laws & Regulations

  • Federal Decree-Law No. 47 of 2022
    Sets the UAE's permanent establishment and UAE-sourced income rules, determining when foreign entities become subject to UAE Corporate Tax.
  • Ministerial Decision No. 97 of 2023
    Transfer pricing rules requiring arm's-length pricing and documentation for cross-border related-party transactions.
  • Cabinet Decision No. 98 of 2024 (amending Cabinet Decision No. 57 of 2020)
    Abolished ongoing Economic Substance Regulations reporting for financial years ending after 31 December 2022.

Summarized for general understanding, not legal advice. Laws and thresholds are updated periodically by the UAE Ministry of Finance and Federal Tax Authority — always confirm your specific position with a registered tax agent.

Talk to Corcess

Ready for compliant, stress-free tax and business support?

Book a free consultation with our FTA-approved team and get a clear plan for your UAE tax and compliance needs.

Call +971 50 271 3700