United Arab Emirates tax residency
for Australians.

The UAE is ranked #1 on our Anchor List because it is the only jurisdiction that combines a genuine zero personal income tax system with codified domestic residence routes, deep banking and a large expatriate infrastructure many Australians now rely on. Its weakness is the mirror of its strength: there is no comprehensive Australian tax treaty, so nothing about the UAE position protects a founder whose Australian exit is not clean on Australia’s tax residency tests.

Project Get Out researchUpdated 19 September 2026960 words

Key facts.

Tax model: PIT 0% CGT 0% on personal investment gains CIT 9% standard, 0% on qualifying Free Zone income, first AED1M tax free Tax basis: no general PIT SPECIAL: none required because PIT is already 0%⁰
Australian DTA: No. No treaty tie-breaker, no reduced Australian withholding¹
Best fit: Made it | Making it | Make it in Crypto | Founder Planning Exit.
Tax law: Cabinet Decision No. 85 of 2022 (tax residency); Federal Decree-Law No. 47 of 2022 (corporate tax), via the FTA legislation library at tax.gov.ae²
Tax residency certificate: Domestic and treaty-purpose certificates issued by the Federal Tax Authority through the EmaraTax portal
PwC reference: taxsummaries.pwc.com/united-arab-emirates³

Becoming a resident is now codified, and there are three routes in.

Since 1 March 2023 the UAE has had a statutory definition of individual tax residence, and it is more accessible than the raw 183-day rule most people assume. A natural person is a UAE tax resident if any one of three tests is met: their usual or primary place of residence and their centre of financial and personal interests is in the UAE; they are physically present for 183 days or more in a rolling 12-month period; or they are present for 90 days or more in a rolling 12-month period while holding a UAE residence visa (or UAE/GCC nationality) together with either a permanent place of residence in the UAE or an employment or business there. The practical consequence for a Get Out client is that a founder with a visa, a leased home and a UAE business can qualify at 90 days rather than 183, and can then apply to the Federal Tax Authority for a tax residency certificate evidencing that position. Two qualifications matter. The certificate is evidence of the UAE position, not an override of the Australian facts, and the 90-day route produces a domestic residence that carries less evidentiary weight for the Australian analysis than a life actually centred in the Emirates.⁴

There is no elective regime because none is needed, but the zero rate has a perimeter.

The UAE levies no PIT on salaries, dividends, interest, rents or capital gains, and no wealth, inheritance or gift tax; the individual tax return simply does not exist for passive and employment income. The perimeter is the federal corporate tax introduced by Federal Decree-Law No. 47 of 2022. A natural person conducting a business or business activity in the UAE falls within CIT at 9% once turnover from that activity exceeds AED 1 million in a calendar year, although wages, personal investment income and personal real estate investment income are expressly excluded. A founder who relocates and continues to run an operating business from Dubai is therefore not automatically outside tax: the business profits may be within the corporate tax net, a UAE permanent establishment of a foreign company can be created, and a free zone entity keeps its 0% rate only while it satisfies the qualifying free zone person conditions. VAT at 5% applies in the ordinary way. The zero-tax headline is real for the person; it is conditional for the business.⁵⁶

What an Australian pays, field by field.

Employment and business income: nil personally, CIT at 9% at entity or sole-business level above the threshold described above. Dividends and interest: nil in the UAE, but Australian-source unfranked dividends, interest and royalties remain subject to Australian withholding at the full domestic rates of 30%, 10% and 30% respectively, because there is no treaty to reduce them. Founder-share gains: the UAE does not tax them, which makes the Australian side of the CGT event I1 decision the whole analysis; there is no UAE entry rebasing question because there is nothing to rebase into. Foreign income generally: untaxed. Net wealth and property taxes: none, although emirate-level fees apply to property transfers and rentals. Inheritance and exit: no death or gift taxes and no exit tax, but succession is the genuine trap in this field, because the default regime for a non-Muslim resident who dies without appropriate arrangements can be Sharia-based intestacy, and a DIFC or ADGM will, or the civil family law options now available, should be part of the relocation file rather than an afterthought.⁷

The Australian interaction is the entire risk, because there is no treaty net.

The UAE does not appear on Treasury’s list of comprehensive Australian income tax treaties. That absence has three consequences. First, there is no tie-breaker: if the ATO later concludes the founder remained an Australian resident under the resides or domicile tests, no treaty allocates them to the UAE, so the Australian domestic exit analysis in Parts IV to VII of the Guide must succeed on its own. Second, Australian-source income keeps its full domestic withholding treatment as above. Third, the deemed disposal choice under CGT event I1 is made knowing that Australia is the only country that will ever tax the pre-departure gain, which tends to favour crystallising at departure where liquidity and valuations allow, rather than electing to leave assets inside Australia’s net indefinitely. The catch to lead with in client conversations: the UAE makes it administratively easy to look resident at 90 days, and that ease is precisely what the ATO discounts. The position that holds is the one where the home, family, banking and decision-making actually moved.⁸⁹

Trace the research

Sources and notes

These numbered notes are preserved from the supplied manuscript so each substantive statement remains connected to its research trail.

Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses, with Cabinet Decision No. 49 of 2023 (natural persons within corporate tax only where turnover from business or business activity in the UAE exceeds AED 1 million per calendar year; wage, personal investment income and real estate investment income excluded). Official texts via tax.gov.ae/en/legislation.↩
Australian Treasury, Income Tax Treaties (current list of comprehensive agreements given force of law by the International Tax Agreements Act 1953 (Cth)), treasury.gov.au/tax-treaties/income-tax-treaties (accessed 24 August 2026). The presence or absence of each jurisdiction is as stated in the relevant entry. A tax information exchange agreement is not treated as a DTA.↩
UAE Cabinet Decision No. 85 of 2022 on Determination of Tax Residency (issued 9 September 2022, effective 1 March 2023), as implemented by Ministerial Decision No. 27 of 2023 and supplemented by Ministerial Decision No. 247 of 2023 (tax residency certificates for treaty purposes). Official texts via the Federal Tax Authority legislation library, tax.gov.ae/en/legislation. Hosted repository copy to be linked before publication.↩
PwC, Worldwide Tax Summaries, United Arab Emirates, Individual, Residence (last reviewed 12 March 2026), taxsummaries.pwc.com/united-arab-emirates/individual/residence (accessed 24 August 2026).↩
UAE Cabinet Decision No. 85 of 2022 on Determination of Tax Residency (issued 9 September 2022, effective 1 March 2023), as implemented by Ministerial Decision No. 27 of 2023 and supplemented by Ministerial Decision No. 247 of 2023 (tax residency certificates for treaty purposes). Official texts via the Federal Tax Authority legislation library, tax.gov.ae/en/legislation. Hosted repository copy to be linked before publication.↩
PwC, Worldwide Tax Summaries, United Arab Emirates, Individual, Residence (last reviewed 12 March 2026), taxsummaries.pwc.com/united-arab-emirates/individual/residence (accessed 24 August 2026).↩
Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses, with Cabinet Decision No. 49 of 2023 (natural persons within corporate tax only where turnover from business or business activity in the UAE exceeds AED 1 million per calendar year; wage, personal investment income and real estate investment income excluded). Official texts via tax.gov.ae/en/legislation.↩
Australian domestic withholding on payments to non-residents, absent treaty reduction: unfranked dividends 30%, interest 10%, royalties 30% (Income Tax Assessment Act 1936 (Cth) Pt III Div 11A; Taxation Administration Act 1953 (Cth) Sch 1 Subdiv 12-F). Fully franked dividends are not subject to withholding.↩
Australian Treasury, Income Tax Treaties (current list of comprehensive agreements given force of law by the International Tax Agreements Act 1953 (Cth)), treasury.gov.au/tax-treaties/income-tax-treaties (accessed 24 August 2026). The presence or absence of each jurisdiction is as stated in the relevant entry. A tax information exchange agreement is not treated as a DTA.↩
Income Tax Assessment Act 1997 (Cth) ss 104-160 (CGT event I1) and 104-165 (choice to disregard); see Part V of the Guide for the full analysis.↩

Acronyms

What these terms mean.

PIT: personal income tax
CGT: capital gains tax
CIT: corporate income tax
DTA: comprehensive double tax agreement with Australia
WW: worldwide taxation
TERR: territorial taxation
REM: remittance basis
SPECIAL: preferential regime for qualifying new residents

Behind Project Get Out

Experience you can trace.

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