United Arab Emirates

Under UAE CT Law, a branch of a non-resident person could be regarded as a PE in the UAE and the income attributable to such branch could be subject to UAE CT.

The UAE does not have a branch profits distribution tax and repatriation of profits between branches and their head offices are not subject to withholding tax (WHT) or other forms of repatriation tax in the UAE.

Separately from the UAE CT, in certain Emirates, branches of foreign banks are taxed under special Bank Tax Decrees/Laws at 20% of their adjusted taxable income. There are certain mechanisms in place to deal with avoidance of double taxation under UAE CT and Emirate tax.