FAQ – Article 13 State Sourced Income

Source: https://mof.gov.ae/corporate-tax-faq/

  1. What determines whether income is sourced from the UAE?

Income will be considered to be sourced from the UAE, if:

the income is derived from a UAE resident;
● the income derived is attributed to a Permanent Establishment in the UAE of a non-UAE resident; or
● the income is derived from activities performed, assets located, capital invested, rights used or services performed or benefited from in the UAE.

The Corporate Tax Law includes a non-exhaustive list of income that is considered as being sourced in the UAE.
A Cabinet Decision may be issued in due course specifying the types of UAE sourced income subject to withholding tax. The UAE withholding tax rate is set at 0%.

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