By Dubai Tax Resident Editorial Team · Last reviewed: October 2026
A double tax treaty is an agreement between two countries that decides which one may tax a given type of income and how to settle a person who is resident in both. The UAE has one of the largest treaty networks in the world, including treaties with the UK, France, the Netherlands, Belgium, Italy, Austria and Finland. There is one major exception for Europeans: the treaty between Germany and the UAE expired at the end of 2021 and has not been replaced, so German leavers cannot rely on treaty protection. See also our UK Statutory Residence Test guide for how the UK decides residence before the treaty applies.
Key facts
- UAE network: well over 100 income tax treaties in force
- UK: UK-UAE treaty in force since 2016
- Germany: no treaty since 1 January 2022; negotiations on a new treaty were announced in 2026
- Tie-breaker: decides your residence if both countries treat you as resident
- Proof: a UAE Tax Residency Certificate is usually needed to claim treaty benefits
- Official list: published by the UAE Ministry of Finance
What does a double tax treaty do?
When you move, two countries may both consider you tax resident: your former country under its domestic rules and the UAE under Cabinet Decision No. 85 of 2022. A treaty resolves this through a tie-breaker test, and then allocates taxing rights for income such as salary, dividends, interest, pensions, rental income and capital gains. It can also reduce withholding taxes on payments from your former country.
The tie-breaker test
Most UAE treaties follow the OECD model. If you are resident in both countries, you are treated as resident only where you have:
- a permanent home available to you; if you have one in both countries,
- your centre of vital interests, meaning closer personal and economic relations; if that cannot be decided,
- your habitual abode, where you spend more time; and finally,
- your nationality, or a mutual agreement between the tax authorities.
In practice, this means that keeping a family home in Europe can undo a move even if you have a UAE visa and spend months in Dubai. Some older UAE treaties also contain special definitions of who counts as a UAE resident individual, so always check the specific treaty text.
Treaties with key European countries
| Country | Treaty with UAE | What it means for leavers |
|---|---|---|
| United Kingdom | In force (2016) | Tie-breaker available; relief on some UK income via form DT-Individual |
| Germany | Expired 31 December 2021 | No tie-breaker; German domestic rules apply in full |
| France | In force | Tie-breaker and allocation rules apply; check exit tax interaction |
| Netherlands | In force | Relevant for protective assessments and pension income |
| Belgium | In force | May matter for exit tax deferral conditions |
| Italy | In force | Tie-breaker available; Italian residence rules still apply first |
| Austria | In force | Allocation of taxing rights on income and gains |
| Finland | In force | Can override the three-year rule if you are treaty-resident in the UAE |
The current list of treaties is published by the UAE Ministry of Finance. Always confirm the status and text of the treaty relevant to you.
Germany: moving without a treaty
Germany allowed its 2010 treaty with the UAE to lapse at the end of 2021. Since then, if you are still considered resident in Germany, for example because you keep a home there, there is no tie-breaker to move your residence to the UAE. German rules such as the exit tax and the extended limited tax liability for German citizens who move to low-tax countries apply without treaty limits. In September 2026 both countries announced that they expect to conclude negotiations on a new treaty, but until it is signed and in force, German leavers need a clean break: no available home in Germany and a clear move of their life and business to the UAE.
How to claim treaty benefits
- Get a UAE Tax Residency Certificate from the Federal Tax Authority. It is the standard proof of UAE residence for treaty purposes.
- File the relevant forms in your former country, such as the UK form DT-Individual for reduced withholding on UK income.
- Keep evidence of your permanent home, family location, economic ties and days spent in each country.
Is your move protected by a treaty?
We check the treaty between your country and the UAE, run the tie-breaker test on your situation and plan the steps to secure your residence.
Frequently asked questions
A double tax treaty is an agreement between two countries that decides which country may tax each type of income and settles residence for people who are resident in both, so the same income is not taxed twice.
Yes. The UK-UAE double tax treaty has been in force since 2016. It includes a tie-breaker for people resident in both countries and can reduce UK tax on some types of income.
No. The 2010 treaty expired on 31 December 2021 and has not been replaced. Both countries announced in 2026 that they expect to conclude negotiations on a new treaty, but none is in force yet.
If you are resident in both countries, the tie-breaker assigns residence to the country where you have a permanent home, then your centre of vital interests, then your habitual abode, and finally your nationality.
The UAE has well over 100 income tax treaties in force, one of the largest networks in the world. The current list is published by the UAE Ministry of Finance.
Usually yes. A UAE Tax Residency Certificate from the Federal Tax Authority is the standard evidence that you are UAE resident for treaty purposes.
Generally not. Exit taxes are charged on gains accrued while you were resident, before you leave, and treaties usually do not prevent them. Treaty status can affect deferral conditions in some countries.
Yes. Finland has a tax treaty with the UAE. If you are resident in both countries, the treaty tie-breaker can make you resident in the UAE for treaty purposes, limiting Finland’s taxing rights.
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Disclaimer: This article provides general information only and is not tax advice. Treaty status and wording vary; check the specific treaty and consult a qualified adviser.