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May 15, 2026
Article 14 defines when a Non-Resident Person has a 'Permanent Establishment' (PE) in the UAE, triggering tax liability on attributable income. A PE can be a fixed place of business (e.g., branch, office, factory) or an agent who habitually exercises authority to conclude contracts on behalf of the non-resident. The article lists exceptions for activities of a preparatory or auxiliary nature, such as storage or purchasing. However, these exceptions do not apply if activities are fragmented to avoid creating a PE. The article also provides rules for dependent versus independent agents, crucial for determining PE status.
Chapter 4 - Taxable Person and Corporate Tax Base
Article 14 - Permanent Establishment
[GTL Notes]
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