United Arab Emirates
Tax residence under the tax decrees of the various Emirates is based upon the French concept of territoriality. Basically, the French territoriality concept taxes profits based on territorial nexus and does not tax profits earned outside the country.
Permanent establishment (PE)
The United Arab Emirates generally follows the definition of a PE in Article 5 of the 2014 Organisation for Economic Co-operation and Development (OECD) Model Tax Convention. Non-resident companies carrying out a trade or business in an Emirate through a PE in that Emirate are prima facie taxable under the relevant Emirate tax decree. The definition of PE generally includes a branch, place of management or other fixed place of business, and an agent that has and habitually exercises authority to conclude contracts on behalf of the non-resident company.