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May 15, 2026

This is not an Official Translation:

Determination of Tax Residency

Cabinet Decision No. 85 of 2022

Issued 2 Sept 2022 – (Effective 1 Mar 2023)

[GTL Notes]

The Cabinet has decided:

  • Having reviewed the Constitution,

  • Federal Law No. 1 of 1972 on the Competencies of the Ministries and Powers of the Ministers and its amendments,

  • Federal Decree-Law No. 13 of 2016 on the Establishment of the Federal Tax Authority and its amendments,

  • Federal Law No. 7 of 2017 on Tax Procedures and its amendments, and

  • Pursuant to the presentation of the Minister of Finance and approval of the Cabinet,

Article 1 - Definitions

In the application of the provisions of this Decision, the following words and expressions shall have the meanings assigned against each, unless the context requires otherwise:

State

:

United Arab Emirates.

Minister

:

Minister of Finance.

Authority

:

Federal Tax Authority.

Person

:

Natural or juridical person.

Tax Resident

:

The Person who is resident of the State as specified in Articles 3 and 4 of this Decision.

Business

:

Any activity conducted regularly, on an ongoing and independent basis by any Person, such as industrial, commercial, agricultural, professional, vocational, service or excavation activities or anything related to the use of tangible or intangible properties.

Residence Permit

:

The permit or authorisation issued by the competent authorities in the State granting the natural person the right to reside or work within the territory of the State and does not include any temporary permit to enter the State for a specified period for the purposes of temporary travel, tourism, sport, medical treatment or any other purpose.

Permanent Place of Residence

:

The place located in the State and available to the natural person at all times.

International Agreement

:

Any bilateral or multilateral agreement, or any other agreement to which the State is a party, that has been ratified by the parties.

Tax Residency Certificate

:

A certificate issued by the Authority proving that the Person is a Tax Resident in the State.

Tax

:

Every federal Tax imposed under the Tax Law, that the Authority is mandated to administer, collect and enforce.

Tax Law

:

Any federal law whereby the Tax is imposed.

Article 2 - Objectives of the Decision

This Decision is intended to determine the requirements and conditions for identifying a Person as a Tax Resident in the State.

Article 3 - Juridical Person