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May 15, 2026

This Decision details conditions where a natural person's presence in the UAE does not create a Permanent Establishment (PE) for a Non-Resident Person, per Article 14 of the Corporate Tax Law. This applies if the presence is temporary and due to exceptional circumstances that are unpredictable and beyond control. The Decision provides examples of such circumstances, including public situations like health measures or travel restrictions, and private ones like personal health emergencies. All specified conditions must be met for this relief to apply, preventing unintended PE creation from unforeseen events.

This is not an Official Translation:

Determination of the Conditions under which the Presence of a Natural Person in the State would not Create a Permanent Establishment for a Non-Resident Person for the Purposes of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses

Ministerial Decision No. 83 of 2023

Issued 10 Apr 2023 – (Effective 15 days after publishing in the Official Gazette)

[GTL Notes]

The Minister of State for Financial Affairs has decided:

Having reviewed the Constitution,
Federal Law No. 1 of 1972 on the Competencies of 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 Decree-Law No. 28 of 2022 on Tax Procedures,
Federal Decree-Law No. 47 of 2022 on Taxation of Corporations and Businesses,

Article 1 - Definitions

Words and expressions in this Decision shall have the same meanings specified in the Federal Decree-Law No. 47 of 2022 referred to above (“Corporate Tax Law”).

The Minister of State for Financial Affairs has decided:

Article 1 - Definitions

Article 2 - Conditions of a Temporary and Exceptional Presence in the State