Businesses in the United Arab Emirates (UAE) generally adopt a corporate form. The following forms of corporate structures exist in the UAE (including the mainland jurisdiction and free zones). Amongst others, the key distinction amongst each of the corporate structure is the extent to which the shareholders or partners in a corporate structure are liable for the obligations of the company or partnership respectively.

Partnerships

• Joint liability company: A joint liability company consists of two or more physical partners, who are severally and jointly liable in all their personal assets for the company's obligations.
• Limited partnership company: A company consisting of joint partners, where at least one joint partner has the capacity of trader and is liable for the company's obligations, and at least one joint partner is a silent partner who is not treated as a trader and shall not be liable for the partnership's obligations except to the extent of the contribution to the partnership's capital.

Companies

• Limited liability company (LLC):  A company that consists of a number of partners that is not less than two and not more than 50, and each of them shall only be liable only to the extent of his share in the capital.
• One person limited liability company: It is permissible for one physical or juristic person to incorporate and own an LLC. The owner of the capital thereof shall be liable only for the obligations of the company to the extent of the capital set out in its constitutive documents.
• Public joint stock companies: A company that consists of not less than five partners and whose capital is divided into equal and negotiable shares. The founders shall subscribe to part of such shares while the remaining shares shall be offered for public subscription. The shareholder shall be liable only to the extent of his share in the capital of the company. Such companies have a minimum issued capital requirement of AED30 million.
• Private joint stock companies: A company wherein the number of shareholders is not less than two. The capital of the company shall be divided into shares of equal nominal value, to be paid in full without offering any shares for public subscription. A shareholder shall be liable only to the extent of his share in the capital of the company. Such companies have a minimum issued capital requirement of AED5 million.

Branch

Foreign companies, wishing to conduct their activities in the UAE, may set up a branch or office in the UAE after obtaining the requisite registrations these companies are deemed to be domiciled in the UAE.

Foundations

Foundations are usually set up in the free zones for charitable purposes and benefiting the public or to manage wealth and distribute it to designated beneficiaries, often family members. A foundation is an independent legal entity, with a legal personality different from its founder.

Foundations Free Zones Entities

The UAE has numerous free zones which have their independent companies regulations. The types of corporate structures that may be set up in each of the free zones will vary from free zone to free zone. However, typically, limited liability companies can be set up in most of the free zones.

The commonly used transparent entities in the UAE include unincorporated partnerships, trusts, and joint ventures. Limited partnership structures may be used for collective investments.

Subject to the operation of the avoidance of double taxation agreements (DTAs), any establishment incorporated in the UAE (including in the free zones) is automatically treated as a UAE resident person (including all the corporate forms) regardless of where its business activities take place.

Since transparent entities do not typically have a separate legal personality, generally, each partner is treated as conducting the business thereof and the residence is determined accordingly.

Lastly, a foreign company may also be treated as a UAE resident person if it is effectively managed and controlled in the UAE. This could depend upon a range of factors. These include:

• where key management and commercial decisions that are necessary for the conduct of the business are in substance made;
• where the controlling shareholders make decision;
• the location of another person or body to which the board has delegated its decision-making powers; or
• the location where the board members or executive management reside.

Generally, corporate tax applies to taxable income at the following rates:

• Taxable Income not exceeding AED375,000 at the rate of 0%; and
• Taxable Income exceeding AED375,000 at the rate of 9%.

In the event of Qualifying Free Zone Persons, corporate tax applies as follows:

• Qualifying Income at the rate of 0%; and
• Taxable Income that is not Qualifying Income at the rate of 9%.

There are no specific tax rates for businesses owned by individuals directly or through transparent entities and generally the rates of corporate tax specified above shall apply.

Taxable profits or taxable income are determined by using the annual accounting income stated in the financial statements (prepared in accordance with the acceptable accounting standards, ie, International Financial Reporting Standards (IFRS) or IFRS for small to medium sized enterprises (SMEs), as applicable) as the starting point.

Adjustments are then to be made to such annual accounting income or profits stated in the financial statements which may include:

• unrealised gains or losses;
• exempt income;
• deductions;
• relief for specific transactions (eg, transactions within a qualifying group);
• transfer pricing adjustments; and
• tax losses.

Generally, taxable persons can prepare financial statements using the receipts basis of accounting rather than the accrual basis of accounting if their revenue does not exceed AED3 million for the relevant tax period.

A Qualifying Free Zone Person (QFZP) may receive benefits related to income from qualifying intellectual property (IP). The Free Zone regulations offer advantages to QFZPs engaged in research and development (R&D) activities that generate qualifying IP.

A QFZP will earn qualifying income from this IP if there is a direct connection, referred to as a "nexus," between the income derived from the qualifying IP and the qualifying R&D expenditures that contributed to it.

However, no similar incentives currently exist for the non-free zone persons.

Some of the key special incentives are as under:

• Free zone persons: Companies set up in the free zones which fulfil certain conditions prescribed under the corporate tax legislations, including qualifying a free zone person and generating qualifying free zone income may avail exemptions from the corporate tax. Generally, the sectors which may (subject to fulfilment of certain conditions) enjoy the maximum level of permissible exemptions include manufacturing and process of goods and materials, holding companies, wealth and investment management services, certain activities relating to ships and aircraft, distribution of goods or materials from a designated zone, and logistics.
• Small businesses: Small business relief is available to small businesses that are residents for corporate tax purposes in the UAE, to facilitate their adaptation to the corporate tax regime. Any eligible Taxable Person (either a Natural Person or a Juridical Person) with revenue of AED3,000,000 or less in a relevant tax period, and in all previous tax periods ending on or before 31 December 2026, can opt to be treated as having no taxable income for that period. Consequently, they will not be required to calculate their taxable income or complete a full tax return.
• Investment funds: An investment fund can be exempt from corporate tax as a qualifying investment fund if it meets certain conditions. These conditions include that such fund:
1. must be regulated by a competent authority in the UAE or a recognised foreign authority;
2. must trade its shares on a recognised stock exchange or widely available to investors;
3. not have a primary purpose that is not the avoidance of corporate tax; and
4. must meet any additional conditions set by the Council of Ministers.
• Business restructuring: Where an entire business or an independent part of it is transferred in exchange for shares or other ownership interests, business restructuring relief may apply to eliminate the impact of corporate tax. This will be subject to the conditions set out in the corporate tax laws.
• Qualifying group: Transfers of assets and liabilities between closely related businesses which typically form part of a group structure may be subject to corporate tax relief which allows such transfers to take place without giving rise to a corporate tax liability. This will be subject to the conditions set out in the corporate tax laws.
• Domestic dividends: Domestic dividends paid by UAE resident companies are exempt from the corporate tax (including where the dividend-paying company itself is exempt from the corporate tax).

In addition, subject to certain conditions, tax exemption may also be available for extractive activities and non-extractive natural resource businesses as detailed in the corporate tax laws.

The key basic rules on loss relief are as follows:

• Carry forward of tax losses: Taxable persons can carry forward their tax losses to offset taxable income in subsequent tax periods, subject to certain conditions. Carried forward tax losses can reduce taxable income by a maximum of 75% in any given tax period. These tax losses must be used in the current tax period before any remaining losses can be carried forward. Losses cannot be carried back.
• Transfer of tax losses: Tax losses may be transferred between taxable persons that are resident juridical persons, subject to conditions such as a minimum 75% direct or indirect ownership interest, a shared financial year, and the use of the same accounting standards. Transferred tax losses can reduce the recipient’s taxable income by a maximum of 75%. The relationship of the recipient taxable person with the taxable person transferring their tax losses must meet the relevant conditions from the start of the tax period in which the tax loss is incurred to the end of the tax period in which the transferred tax loss is used.

The key limits imposed generally on the deduction of interest are as follows.

The General Interest Deduction Limitation Rule defines the amount of interest that is deductible as “net interest expenditure”, which is the difference between the interest expenditure incurred (including any carried forward net interest expenditure) and the interest income derived during a tax period.

When the net interest expenditure exceeds AED12,000,000 in a tax period, the amount of deductible net interest expenditure is limited to the greater of 30% of Earnings Before Interest, Tax, Depreciation, and Amortisation (EBITDA) for that tax period, or the de minimis threshold of AED12,000,000. Additionally, any net interest expenditure disallowed in a tax period due to the General Interest Deduction Limitation Rule can be carried forward and utilised in the subsequent ten tax periods, subject to the same conditions.

There are also specific interest deduction limitations to prevent abuse through related party transactions. No deduction is allowed for interest expenditure incurred on a loan obtained from a related party if the loan is used for dividends, profit distribution, redemption of share capital, capital contributions, or acquiring ownership interests in a business that becomes a related party following the acquisition.

In the UAE, a tax group can be formed by a parent company making an application to the Federal Tax Authority and each of its subsidiary companies seeking to become members of the tax group. This is subject to meeting certain conditions stipulated under the corporate tax laws. These are:

• each company shall be a resident juridical person under the corporate tax laws and if applicable, under a relevant DTA;
• parent company must directly or indirectly own at least 95% of the share capital or voting rights in the subsidiary and be entitled to at least 95% of the subsidiary’s profits and net assets;
• parent company or subsidiary must not be considered resident for the purposes of tax in another jurisdiction under a relevant DTA;
• none of the companies should be an exempt person or qualifying free zone person;
• each company shall have the same financial year; and
• each company shall apply the same accounting standards for the preparation of financial statements. 

The parent company represents the group and is responsible for tax compliance. The parent company and subsidiaries are jointly and severally liable for the corporate tax during their membership of the group.

Unutilised tax losses of a subsidiary joining the tax group become carried forward losses of the tax group but can only offset taxable income attributable to the subsidiary. The 75% cap on the utilisation of carried forward tax losses applies to the tax group.

If a new subsidiary joins an existing tax group, the unutilised tax losses of the existing group cannot be used to offset the taxable income of the new subsidiary. If a subsidiary leaves a tax group, it will retain any unutilised tax losses incurred before joining the group, but any tax losses incurred while it was a part of the tax group will remain within the tax group. 

Tax losses can be transferred between resident juridical persons if certain conditions are met, reducing the recipient’s taxable income by up to 75%.

If no consolidation is permitted, groups can utilise separate company losses through the transfer of tax losses.

In UAE, there is no distinction between gains from the sale of capital assets and non-capital (revenue) assets. Capital gains from asset disposals are included in annual taxable income like other business income.

Capital gains on the sale of shares may be exempt from corporate tax under the participation exemption regime, which applies to gains from a participating interest in both foreign and domestic juridical persons. Additionally, there is tax relief for capital gains arising from intra-group transfers, reorganisations, and restructurings. Other capital gains are treated as ordinary income and subject to corporate tax.

A participating interest means a significant long-term ownership interest in the shares and capital of a juridical person that provides the basis for the exercise of some level of control or influence over the activities of participation. It exists when the specific conditions stipulated under the Corporate Tax laws are met.

In addition to corporate tax, some other taxes may apply to incorporated businesses in the UAE on transactions:

• Withholding tax: The UAE currently has mechanisms and machinery both legislative and institutional for imposition of the withholding tax. However, the rate for withholding tax is presently 0% so in practice, no withholding tax is levied.
• Value-added tax (VAT): The standard VAT rate in the UAE is 5%. This applies to most goods and services unless specifically exempted or zero-rated. Businesses need to comply with VAT regulations, including registration, filing returns, and paying VAT collected to the Federal Tax Authority.

The following notable taxes may be applicable:

• Customs duties: Importing goods into the UAE may incur customs duties.
• Excise tax: Certain products, such as tobacco, energy drinks, and carbonated beverages, are subject to excise tax. This tax is aimed at reducing the consumption of unhealthy goods and is levied at varying rates depending on the product category.
• Real estate transfer fees: Transactions involving real estate transfer may be subject to transfer fees, typically a percentage of the property’s sale value. The rate can vary depending on the Emirate and specific regulations in place.

As per the estimates provided by the Ministry of Economy of the UAE, around 90% of the private companies in the UAE are family businesses or closely held local businesses, employing more than 70% of the sector’s workforce and contributing about 40% to the GDP of the UAE. Therefore, there is a huge segment of closely held local businesses operating in corporate form.

The UAE does not have different corporate tax rates for corporations and individual professionals.

It may however be noted that individuals (or natural persons) are subject to corporate income tax only if they conduct "business" activities pursuant to a trade licence and generate annual income exceeding AED1,000,000.

Income generated by natural persons from employment, personal investments, and real estate investments is not taxable.

There are currently no specific rules preventing closely held corporations from accumulating earnings for investment purposes.

Individuals will not be taxed on dividends from and on gain on the sale of shares in closely held corporations unless engaged in the business of holding and trading shares pursuant to a commercial licence.

Individuals will not be taxed on dividends from and on gain on the sale of shares in publicly traded corporations unless engaged in the business of holding and trading of shares pursuant to a commercial licence.

In the UAE, the withholding tax rate is currently set at 0% for payments made to non-residents for categories such as interest, dividends, and royalties. This means that no withholding tax is deducted from these types of payments.

If the withholding tax rate changes in the future, non-resident persons who become subject to corporate tax can reduce their corporate tax payable by any withholding tax that has already been deducted in the same tax period, known as a withholding tax credit. Any excess withholding tax credit will be refunded.

Currently, the local tax authority does not collect withholding taxes on interest, dividends, and royalties due to the 0% rate. However, the mechanism for withholding tax appears to be in place should the rates change.

UAE has signed Double Taxtation Agreements (DTAs) with more than 140 countries. The notable jurisdictions include the United States, United Kingdom, Germany, France, China, India and Saudi Arabia. Public and private companies, investment firms, air transport firms, and other businesses operating in the UAE, along with residents, benefit from the DTAs.

While there are no known precedents of local tax authorities challenging the use of treaty country entities by non-treaty country residents, the possibility of such challenges in the future cannot be excluded.

These could be based on, amongst others, the wording and clauses of a particular DTA.

Taxable persons, including inbound investors operating through a local corporation, must maintain detailed transfer pricing documentation, including a master file and a local file if the thresholds prescribed under the corporate tax law are met. Preparing and maintaining transfer pricing documentation and disclosures imposes a significant compliance responsibility including costs and administrative workload.

Generally, related-party transactions including any Related-Party Limited Risk Distribution Agreements for the sale of goods or provision of services must be conducted at arm's length. This means that the prices and terms should be comparable to those between independent parties under similar conditions.

Federal Tax Authority can and has the power to adjust taxable income if it determines that the pricing of related-party transactions does not reflect arm's length terms.

The UAE's transfer pricing rules are, by and large, in accordance with the OECD standards, particularly in the application of the arm’s length principle, documentation requirements, and the need for transparency in related party transactions.

UAE tax authorities may revisit past years if "new information" suggests non-arm's length transactions (subject to any limitation provisions).

While data on successful resolutions through DTA Mutual Agreement Procedure (MAP) is limited, as inquiries and potential disputes rise, the use of MAP might become more common.

If a foreign tax authority makes an adjustment to a transaction or arrangement involving a taxable person to meet the arm’s length standard, the taxable person can make an application to the FTA to make a corresponding adjustment to its UAE taxable income.

In addition, where any adjustments result in double taxation for MNE Groups operating in multiple jurisdictions, the MAP article in DTAs allows competent authorities in partner jurisdictions to interact with the intent to resolve international tax disputes involving cases of double taxation where the same profits have been taxed in two jurisdictions.

Unlike local subsidiaries, local branches are not treated as separate legal entities but as an extension of their “parent” or “head office”. Local branches of non-local corporations would generally be subject to the UAE corporate tax just like local subsidiaries of non-local corporations unless the activities undertaken by the branch do not give rise to any Permanent Establishment (PE) in the UAE for corporate tax.

Generally, capital gains of non-residents from selling shares in UAE local corporations are subject to UAE corporate tax. Such income is considered UAE-sourced and, thus, taxable.

The taxation of capital gains from selling shares in a non-local holding company owning a UAE corporation depends on whether the income is UAE-sourced. Generally, such indirect gains may also be subject to tax if connected to UAE immovable property or other UAE interests.

DTAs can mitigate or reduce the tax on capital gains. Specific provisions in DTAs override domestic tax rules, potentially exempting capital gains from UAE tax depending on the treaty terms.

There are currently no change of control provisions in the corporate tax law.

The transfer pricing provisions in the UAE Corporate tax law reflect the use of the following methods to ensure that transactions between related parties reflect arm’s length pricing:

• Comparable Uncontrolled Price Method (CUP);
• Resale Price Method (RPM);
• Cost Plus Method (CPM);
• Transactional Net Margin Method (TNMM); and
• Profit Split Method (PSM).

Generally, CUP, RPM, and CPM methods are traditionally considered the most direct for determining arm’s length conditions between related or associated parties. TNMM and PSM are transactional profit methods which are usually suitable for situations where parties make unique contributions, engage in highly integrated activities, or have limited publicly available data on third parties.

No specific standards have been stipulated for allowing a deduction for payment by local affiliates for management and administrative expenses incurred by a non-local affiliate. However, please note that such deductions or payments must comply with the arm’s length principle.

The UAE regulates related-party borrowing by foreign-owned local affiliates (FOLAs) from non-local affiliates (NOLAs) to prevent artificial inflation of expenses and potential tax base erosion. This is achieved through two key mechanisms:

• Transactions between related parties, like FOLAs and NOLAs, must adhere to the arm's length principle. This principle ensures the interest rate charged on the loan reflects what unrelated parties would agree on under similar circumstances.
• The UAE has a general interest limitation rule restricting the interest expense a company can deduct for tax purposes. This typically limits deductible interest to 30% of the company's EBITDA.

Generally, foreign-sourced income of local corporations is not exempt from the corporate tax.

Income of foreign branches or foreign permanent establishments of a UAE business will be included in the taxable income and UAE corporate tax return of their UAE business. 

In addition, please note that in case any foreign juridical person (which is for example, a subsidiary of a local corporation) is effectively managed and controlled in the UAE as per the criteria in the corporate tax laws, it may be treated as a resident entity for UAE corporate tax purposes.

However, appropriate tax reliefs and exemptions may be claimed in respect of such foreign-sourced income by local corporations including:

• income from a foreign permanent establishment;
• dividends from foreign subsidiaries;
• income qualifying under the participation exemption;
• any reliefs under any DTA; and
• foreign tax credits.

If the foreign income is exempt, any expenses incurred while earning such exempt foreign income will not be deductible.

Dividends and other profit distributions received by a local corporation from a foreign juridical person (or a foreign subsidiary) may be exempted if the local corporation holds a "participating interest" in such foreign juridical person.

A "participating interest" means a significant long-term ownership interest in the shares and capital of a juridical person that provides the basis for the exercise of some level of control or influence over the activities of participation. It exists when the specific conditions stipulated under the corporate tax laws are met.

Generally, the use of intangibles developed by local corporations in their business by non-local subsidiaries may have corporate tax implications. More specifically, any such transaction will be expected to be on an arm’s length basis and comply with transfer pricing requirements.

To avoid such implications, companies under common ownership may seek to be treated as a qualifying group if certain conditions stipulated under the corporate tax laws are met. These include:

• taxable persons being juridical persons that are resident persons or non-residents having a permanent establishment in the UAE;
• either taxable person having a direct or indirect ownership of at least 75% in the other taxable person or a third person having direct or indirect ownership interest of at least 75% in each of the taxable persons;
• none of the companies should be an exempt person or qualifying free zone person;
• each company shall have the same financial year; and
• each company shall apply the same accounting standards for the preparation of financial statements. 

If such conditions are met, then transfers between qualifying groups may not be subject to the strict applicability of the arm’s length principles.

See 1.3 Determining Residence of Incorporated Businesses and 6.1 Foreign Income of Local Corporations.

Presently, the UAE does not have specific Controlled Foreign Corporation (CFC) rules that directly tax local corporations based solely on the substance of their non-local affiliates.

However, it must be noted that:

• income generated by a tax resident of the UAE from its controlled foreign corporation may be subject to tax; and
• a foreign corporation may be treated as a UAE resident and subject to tax where it is effectively managed and controlled in the UAE. See 1.3 Determining Residence of Incorporated Businesses and 6.1 Foreign Income of Local Corporations.

See 2.7 Capital Gains Taxation.

The corporate tax laws stipulate general anti-abuse rules. The salient features of such rules are as follows:

• It applies where the purpose of entering any transactions or arrangements is not a valid commercial purpose or a non-financial purpose that reflects the economic reality.
• It also applies where the main purpose or any of the main objectives of any transactions or arrangements is to get a corporate tax advantage that does not comply with the purpose and objectives of the corporate tax law. Such advantages may include:
1. obtaining refund or an increased refund of corporate tax;
2. avoiding or reducing the corporate tax payable;
3. delaying the payment of corporate tax or adjust the refund; or
4. avoid the obligation of deduction or calculation of the corporate tax.

There are no pre-determined routine audit cycles. The Tax Authority may decide to conduct a tax audit at any time.

Before deciding to conduct a tax audit, it shall consider:

• the necessity for protecting the integrity of the tax system;
• the responsibility of the person to comply with the corporate tax laws;
• tax revenue expected to be collected; and
• the compliance and administrative burdens on both the persons and the authority related to performing the tax audit.

UAE is a party to the G20/OECD Inclusive Framework on Base Erosion and Profit Sharing (BEPS) since 2018. The key changes implemented so far include:

• Implementing the rules relating to the economic substance (BEPS Action 5);
• Signing the Multilateral Instrument (BEPS Action 6 and 15);
• Transfer pricing documentation and introducing Country-by-Country (CbC) reporting (BEPS Action 13);
• Implementing Mutual Agreement Procedures and amending the DTAs (including BEPS Action 14); and
• Implementing the Common Reporting Standard (CRS) to allow the automatic exchange of information and ultimate beneficial ownership.

The UAE government has exhibited a proactive attitude towards implementing the BEPS standards and recommendations to achieve tax transparency and prevention of harmful tax practices. This is evident from the various steps taken, see 9.1 Recommended Changes.

Pillar One of BEPS is already in the process of implementation with significant legislative and regulatory measures already taken. For Pillar Two of BEPS, during the OECD Regional Forum held in Dubai in September 2023, the Ministry of Finance of the UAE made an informal announcement that the UAE will defer the implementation of the Pillar Two rules until 2025.

The implementation of Pillar One of BEPS impacts most of the businesses in the UAE. The implementation of Pillar Two of BEPS is likely to impact Multinational Groups (MNEs) with a presence in the UAE. Such MNEs will be required to ensure that they meet global tax standards.

The international tax has a high profile in the UAE. This is demonstrated by the UAE’s continued commitment to international tax standards in recent years. In September 2023, the Ministry of Finance of UAE, in cooperation with OECD, hosted the Pillar Two regional forum, as a part of the UAE’s commitment to international standards around taxation. This event also included a helpful workshop on Pilar Two.

The UAE adheres to a competitive tax policy to underpin and maintain its position as a suitable and attractive economic hub globally.

The recent imposition of the corporate tax and reliefs and exemptions provided to various sectors and entities (which could lead to tax at the rate of 0% or no tax at all) are indicative of such adherence. As an illustration, subject to meeting certain requirements, entities established in the free zone may pay tax at the rate of 0% on their qualifying income.

Similarly, at present there is no income tax on the salaries earned by individuals or income from personal investments that are not in the course of business.

It remains to be seen whether, with the implementation of BEPS, UAE will reduce the number of incentives or relieves offered to certain types of establishments or sectors. However, there is no such indication yet except in the case of MNEs which may be impacted once Pillar Two is implemented.

Such key features are not currently applicable.

The recommendation of BEPS with respect to the hybrid instruments may be implemented in the UAE to ensure compliance and prevent tax base erosion.

Generally, foreign-sourced income is not taxed in the UAE subject to certain exemptions. See 2.5 Imposed Limits on Deduction of Interest.

There are no specific CFC rules in vogue. See 1.3 Determining Residence of Incorporated Businesses and 6.1 Foreign Income of Local Corporations regarding with the treatment of foreign corporations effectively managed and controlled in the UAE. 

The UAE has established several anti-avoidance measures which include the requirements of economic substance (ESR) and transfer pricing. These measures are likely to have an impact on both inbound and outbound investors by making them comply with certain stringent conditions as a part of tax compliance and/or seeking any advantages or relief under the corporate tax law.

The introduction of transfer pricing regulations (in line with BEPS Action 13) is a material change in the UAE. It requires the taxable persons, particularly the related or associated parties to conduct the transaction amongst themselves at arm’s length subject to certain specified exemptions and relieves.

In addition, the taxable persons are now also required to maintain the documentation with respect to such transactions.

Introducing transfer pricing documentation and country-by-country (CbC) reporting (BEPS Action 13) has been implemented in the UAE and is a welcome change aimed at adherence to best practices relating to tax regulation.

No such changes have occurred.

From 1 January 2018, the UAE require non-resident vendors providing digital services to consumers based in the UAE to register for the VAT and collect the VAT notwithstanding the number of sales for such services.

There are currently no such provisions. Please note that presently, the rate of withholding tax is 0% so in essence, no withholding tax is applicable in the UAE.