AE has 9% CIT (since 2023) but Free Zones still 0%. FTA TRC in 5 working days. New Protocol 2024 adds anti-abuse — DIFC SPVs, Golden Visa holders, DP World/Emirates, DMCC crypto/gold traders, ADGM funds, family offices.
Treaty WHT rates: dividends 10% · interest 10% · royalties 15% · fees for technical services (FTS) 15%. Without the DTA, the destination state would withhold 15–30%.
Service-PE threshold: 183 days per 12-month rolling. Capital gains: Generally taxable only in residence state; real-property exception. MLI: covered (Principal Purpose Test applies).
Our workflow (typ. 30–60 days): (1) cross-border tax mapping (2) select the applicable treaty article (3) request Thai CoR (RO.22) from Revenue Dept. (4) request TRC from Revenue Department + FTA UAE (5) file with the withholding agent (PND.54 / PND.1 / PND.50) (6) Substance & beneficial ownership file (7) MAP filing if disputed (8) Annual TP report.