01
Effective status
The protocol of 5 November 2022 entered into force on 5 May 2025; its principal changes apply from 1 January 2026 and include BEPS/PPT, an updated MAP and corresponding adjustment.
This editorial overview does not replace the official treaty and protocol, domestic law or a factual analysis of the income recipient.
02
Dividends
General limit 15%; 5% for a company holding at least 10%; 0% for specified government and pension bodies.
03
Interest
Treaty limit 0%.
04
Royalties
Treaty limit 0%.
05
Applying the treaty
UAE residence, beneficial ownership, PPT, substance, the special switch-over rule and Swiss withholding formalities require testing. A UAE company or foundation does not itself create treaty relief. A treaty rate is a maximum source-state limit, not an automatic rate. Before payment, test residence, beneficial ownership, minimum holding and holding period, PPT, substance, domestic law and the relief-at-source, notification or refund procedure.
06
Practical sequence
- Determine residence and the relevant tax period
- Classify the income and beneficial recipient
- Test the holding, holding period, PPT and business purpose
- Prepare certificates, forms and substance evidence
- Coordinate withholding, notification or refund and MAP where needed
↗