UAE can be used favorably as the location for the ultimate holding company for a group that is relocating to a new jurisdiction or on formation of a new publicly traded entity with worldwide activities

1. *
DUBAI
INTERNATIONAL TAX ASPECTS*

2. TAX INCENTIVES
• No Corporation Tax
• No Personal Tax
• 100% ownership in Free Zones (FZs)
• DTTs with 80 countries
• No foreign exchange controls, trade barriers or quotas
• No restrictions on repatriation of funds
• Strong investor incentives and protection
• Easy access to key decision-makers
Unique window of opportunity, as UAE IBCs combined with the benefits of FZs and the
extensive network of DTTs make UAE a very attractive proposition

3. UAE CORPORATE STRUCTURES
• UAE corporate vehicles can be used as intermediate holding companies in the following
circumstances:
 For groups investing outside UAE aiming at dividend income streams
 To hold overseas subsidiaries
 To benefit from favourable withholding tax provisions
 Where a jurisdiction is required that does not have CFC rules
 To avail of the favourable repatriation provisions under UAE Tax Law
 Suitable for a fund or investment vehicle, as there is no tax on transactions in
securities
 Where it may be important to achieve a tax free unwind in future
 To hold real estate companies for a tax free disposal of property
 To hold intellectual property companies
• UAE can be used favourably as the location for the ultimate holding company for a group
that is relocating to a new jurisdiction or on formation of a new publicly-traded entity with
worldwide activities

4. WHEN UAE FZ CAN BE USED
• Establishing a Free Zone (FZ) entity is a useful international tax planning tool
• Combine FZ with an IBC (RAK): confidentiality and nominees possible
• Global head office company: countries having DTTs with UAE
• Dubai can be utilized for:
 Residence and domicile of directors and senior staff to reduce/eliminate tax in home
country
 Holding company (which has fiscal tax residence in UAE) to receive dividends from a
subsidiary which relies on DTT

5. WHAT UAE IBC (RAK) CAN BE USED
• International trading and holding
• Anonymity is secured as nominees can be used and no public registry
• Easy to set up and maintain
• When no withholding taxes exist in the domestic country in case of subsidiary
such as Cyprus, Malta

6. UAE AS HQ FOR EUROPEAN HOLDING ENTITIES
• UAE has concluded 80 DTTs
• DTTs enable investors to reap tax benefits of a UAE based entity to hold investments
worldwide and also foreign investors to set up business in UAE
• Until recently countries were hesitant to conclude DTT agreements with no/low tax
jurisdictions but this changed recently as newer treaty partners have realized the
advantages of inward investments by wealthy countries such as UAE
• Groups/companies in countries having DTTs with UAE that use the exemption method can
be ideally used to invest in UAE with significant overall tax savings as profits, dividends etc
are reduced
• The most attractive DTT countries are those when sources of the UAE income are exempted
altogether, in which case no tax is levied
• Groups/companies in countries having DTTs with UAE that use the credit method are not
favourable as only credit for foreign taxes against domestic tax liability is allowed. However,
the tax is due when remitted

7. CONSIDERATIONS
• Controlled foreign companies (CFCs)
• Beneficial ownership
• Avoidance of abuse
• Economic substance
• Tax residence certificates

8. LOW OR ZERO WITHHODLING TAX RATES
Below is a list of countries where the UAE offers the best way out of the source jurisdiction for
dividends, interest, royalties and capital gains (not associated with immovable property or a
permanent establishment in the source country) payable to a company considered tax resident in
UAE under the respective DTT:
Austria: 0%-0%-0%-0%
Bulgaria: 5%-2%-5%-0%
China: 7%-7%-10%-0%
Georgia: 0%-0%-0%-0%
Indonesia: 10%-5%-5%-0%
Mozambique: 0%-u*-5%-0%
Netherlands: 5%-0%-0%-0%
India: 10%-12.5%-10%-0%
Poland: 5%-5%-5%-0%
*u = unlimited (no treaty protection)

9. Austria Belgium Cyprus Finland France
Establishing HoldCo
Substance requirement No No No No No
CFC or equivalent legislation No No No Yes Yes
Corporate tax rate 25% 33.99% 12.5% 20% 33.3%
Dividends received by HoldCo
Tax on dividends Exempt 95% Exempt Exempt Exempt 95% Exempt
Any required holding period N/A or 1 year
continuous ownership
1 year N/A N/A 2 years
Required percentage ownership N/A or 10% 10% or acquisition
cost of at least €2.5
mn
N/A 0%-25% 5%
Treatment of subsidiaries
Foreign subsidiary to pay tax in its
own jurisdiction for any exemption
in HoldCo jurisdiction to apply
No Yes, similar to
Belgian corporate
income tax
No Generally, no No
Any required holding period 1 year continuous
ownership prior to
disposal
1 year N/A 1 year 2 years
Required percentage ownership 10% N/A N/A 10% of share capital 5%
COMPARISON OF SELECTED FEATURES WITH UAE DTT

10. Germany Italy Luxembourg Netherlands Poland
Establishing HoldCo
Substance requirement
No No No
Generally no, yes
only for financial
service entities
No
CFC or equivalent legislation Yes Yes No No Yes
Corporate tax rate Generally 30.175%-
33.32% in major cities
27.5%+regional
tax at 3.9%
(ordinary rate)
28.59% (incl the
unemployment fund
surcharge)+6.75%
Municipal business tax
20%-25% 19%
Dividends received by HoldCo
Tax on dividends 95% exempt 95% Exempt Exempt or N/A Exempt Exempt/taxable with
credit for foreign tax
Any required holding period Generally no holding
period is required
N/A 1 year or commitment
to hold for 1 year
N/A 2 years
Required percentage ownership Corporate income tax:
10%/municipal trade
tax: 15%. Both may be
reduced under a treaty
N/A 10% or acquisition cost
of at least €1.2mn
5% 10%/25%/75%
Treatment of subsidiaries
Foreign subsidiary to pay tax in its
own jurisdiction for any exemption
in HoldCo jurisdiction to apply
No No 10.5% if non EU No No
Any required holding period N/A 12 Months 1 year or commitment
to hold for 1 year
N/A N/A
Required percentage ownership N/A N/A 10% or acquisition cost
of at least €6mn
5% N/A

11. Portugal South Africa Spain Sweden Switzerland
Establishing HoldCo
Substance requirement No No Yes No No
CFC or equivalent legislation Yes No Yes Yes No
Corporate tax rate 12.5%-27.5% 28% 30% 22% 25%
Dividends received by HoldCo
Tax on dividends Exempt Generally
exempt
Exempt if
certain
requirements
are met
Depends Exempt
Any required holding period 24 months N/A 1 year N/A 1 year N/A
Required percentage ownership 5% 10% 5% or
acquisition
cost greater
than €20mn
N/A or 10% of
votes/10% of
share capital
10% or market
value of CHF 1mn
Treatment of subsidiaries
Foreign subsidiary to pay tax in its own
jurisdiction for any exemption in HoldCo
jurisdiction to apply
No No Yes Yes No
Any required holding period 24 months N/A 1 year N/A/ 1 year 12 months
Required percentage ownership 5% 10% 5% or
acquisition
cost greater
than €20mn
N/A or 10% of
votes
10%

12. TAX RESIDENCE IN DUBAI
• With an FZ company which must have physical presence (even a flexi-desk/office suffices),
foreign owners and executives can have UAE residence permits and obtain tax residence
certificates
• For a personal tax residence certificate from the Ministry of UAE, the requirements comprise
of request letter, passport copy and valid visa copy, bank statements for the last 6 months,
certificate from the company stating the activity and source of income and a fee of AED 1.000
(US$300)
• Banking institutions in UAE and many outside consider UAE tax residence certificates as
sufficient proof of tax residency in the UAE

13. STRUCTURING INVESTMENT
WITH UAE INTERMEDIATE COMPANY - 1
• No WHT on distribution of dividends by the
UAE Co to the shareholders in/outside the
UAE
• UAE Co dividend income from its
investment in Swiss Co is exempt
• Swiss Co dividends are taxed at 5% in
Switzerland
• When UAE Co transfers shares of Swiss Co,
the capital gains are not taxed in
Switzerland or the UAE
Dividend is tax exempt / no WHT
Capital gains
on share transfer
is tax exempt
Dividend is reduction of WHT
from 35% to 5%
UAE Co
Participation in
Swiss Co
Shareholder
Outside the UAE

14. • No WHT on distribution of dividends by the
UAE Co to the shareholders in/outside the
UAE
• UAE Co dividends, interest, royalties from
Austria Co are exempt
• Austrian Co dividends and interest are
exempt. If no treaty, tax would be withheld
at 25% or 20% respectively
• When UAE Co transfers shares of Austrian
Co, the capital gains are not taxed in
Austria or the UAE
STRUCTURING INVESTMENT
WITH UAE INTERMEDIATE COMPANY - 2
Dividend is tax exempt / no WHT
Capital gains
on share transfer
is tax exempt
UAE Co
Participation in
Austrian Co
Shareholder
Outside the UAE
Dividend is tax exempt

15. STRUCTURING IP INVESTMENT
WITH UAE INTERMEDIATE COMPANY - 3
UAE Co
Operating Company
Parent Company
IP assets
Licensing Royalties/ Capital Gains
• UAE Co dividends, interest, royalties and
capital gains are 100% tax exempt
• Royalty payments are deductable at
licensee level
• Royalty payments made with applicable
withholding tax with each tax treaty
country

16. Dividend is reduced at WHT
as per applicable tax treaty
rate
• No WHT on distribution of dividends by the
UAE Co to the shareholders in/outside the
UAE
• UAE Co dividend income from its
investments in operating Co is exempt
• Operating Co dividends are exempt
• When UAE Co transfers shares of Operating
Co the capital gains are not taxed in
Operating Co Country or the UAE
Dividend is tax exempt / no WHT
Capital gains
on share transfer
is tax exempt
UAE Co (IBC)
Company in
a Treaty Country
Nominee Shareholder,
Corporate Directors
NOMINEE STRUCTURE
WITH UAE INTERMEDIATE COMPANY - 4

17. UAE NETWORK OF DTT
Recipient Dividends % Interest % Royalties %
Albania - - -
Algeria - - 10
Armenia -/3 - 5
Austria - - -
Azerbaijan 5/10 -/7 5/10
Bangladesh - - -
Barbados - - -
Belarus 5/10 5 5/10
Belgium -/5/10 -/5 -/5
Benin - - -
Bosnia & Herzegovina -/5/10 - 5
Brunei - - -
Bulgaria -/5 -/2 -/5
Canada 5/10/15 -/10 10
China 7 7 10
Cyprus - - -
Czech Republic -/5 - 10
Egypt - -/10 10
Estonia - - -
Fiji - - -
Finland - - -
France - - -
Georgia - - -
Germany 5/10/15 - 10
Greece -/5 -/5 -/5
Guinea - - -

18. Recipient Dividends % Interest % Royalties %
Hong Kong - - -
Hungary - - -
India 10 -/5/12.5 10
Indonesia 10 -/5 5
Ireland - - -
Italy 5/15 - 10
Japan - - -
Jordan - - -
Kazakhstan 5 10 10
Kenya - - -
Korea, Republic of 5/10 -/10 -
Latvia -/5 -/2.5 5
Lebanon - - 5
Libya - - -
Lithuania - - -
Luxembourg 5/10 - -
Malaysia 10 -/5 10
Malta - - -
Mauritius - - -
Mexico - - -
Mongolia - - 10
Montenegro -/5/10 -/10 -/5/10
Morocco -/5/10 -/10 -/10
Mozambique - - -/5
Netherlands 5/10 - -
New Zealand 15 -/10 10

19. Recipient Dividends % Interest % Royalties %
Pakistan 10/15 -/10 12
Palestine - - -
Panama 5 -/5 5
Philippines -/10/15 -/10 10
Poland -/5 -/5 5
Portugal 5/15 -/10 5
Romania -/3 -/3 3
Russia - - -
Serbia -/5/10 -/10 10
Seychelles - - 5
Singapore 5 -/7 5
Slovenia -/5 -/5 -/5
Spain 5/15 - -
Sri Lanka -/10 -/10 10
Sudan - - 5
Switzerland 5/15 - -
Syria - -/10 18
Tajikistan - - 10
Thailand 10 10/15 15
Tunisia - 2.5/5/10 7.5
Turkey 5/10/12 -/10 10
Turkmenistan - - 10
Ukraine -/5 -/3 -/10
Uruguay - - -
Uzbekistan -/5/15 -/10 10
Venezuela 5/10 10 10
Vietnam -/5/15 -/10 10
Yemen - - 10

20. Thank you