Website Last updated:

May 15, 2026

This guide explains the UAE Corporate Tax obligations for Non-Resident Persons, defined under Article 11(4). It clarifies that a Non-Resident is taxable if they have a Permanent Establishment in the UAE or derive State Sourced Income. The guide provides an in-depth analysis of what constitutes a Permanent Establishment under Article 14, distinguishing between the fixed place and agency tests. It details the specific exceptions for preparatory or auxiliary activities and discusses the critical role of Double Taxation Agreements, which may override domestic law provisions on taxability and residence.

Non-Resident Persons

Corporate Tax Guide | CTGNRP1

October 2023

1. Glossary

2. Introduction

2.1. Overview
2.2. Purpose of this guide
2.3. Who should read this guide?
2.4. How to use this guide
2.5. Legislative references
2.6. Status of this guide

3. Definition of a Non-Resident Person

4. When is a Non-Resident Person required to register for Corporate Tax purposes?

4.1. Juridical persons
4.2. Natural persons

5. What income of a Non-Resident Person is subject to Corporate Tax in the UAE?

5.1. Income attributable to a Permanent Establishment or nexus
5.2. Business or Business Activities of a non-resident natural person that are subject to Corporate Tax
5.3. State Sourced Income
5.4. State Sourced Income and Withholding Tax
5.5. State Sourced Income and Permanent Establishment
5.6. State Sourced Income and nexus
5.7. Small business relief: unavailable to a Non-Resident Person
5.8. Exempt income from operating aircraft or ships in international transportation
5.9. Interaction of the Corporate Tax Law with Double Taxation Agreements

6. Other UAE Corporate Tax requirements for a Non-Resident Person

6.1. Standalone Financial Statements and attribution
6.2. Tax Return submission
6.3. Record keeping

7. Permanent Establishment

7.1. Overview
7.2. Fixed place Permanent Establishment
1. 7.2.1. Essential factors determining the existence of a fixed place Permanent Establishment
  7.2.2. Immaterial factors for determining the existence of a fixed place Permanent Establishment
  7.2.3. Specific inclusions to a fixed place Permanent Establishment
  7.2.4. Preparatory or auxiliary activities
7.3. Agency Permanent Establishment
1. 7.3.1. When does a Person create an agency Permanent Establishment for a Non-Resident Person?
  7.3.2. Independent agents: When does a Person not create an agency Permanent Establishment for a Non-Resident Person?

8. State Sourced Income

9. Nexus in the UAE

10. Annexures

10.1. Annexure 1 – Relevant extract of Double Taxation Agreement between the UAE and Country I
10.2. Annexure 2 – Relevant extract of Double Taxation Agreement between the UAE and Country U

11. Updates and Amendments

Contents

Glossary