Answer:
Yes. Foreign juridical persons will be subject to UAE Corporate Tax if they either:
1. Operate through a Permanent Establishment (PE) in the UAE; or
2. Are considered Resident Persons by being effectively managed and controlled in the UAE. Merely earning UAE-sourced income without a PE or fulfilling residency criteria does not trigger UAE CT registration or liability.
Key Requirements & Rules:
• Permanent Establishment: Defined under Article 14 of Federal Decree-Law No. 47 of 2022 as having a fixed place or representative in the UAE carrying core business activities beyond preparatory or auxiliary roles.
• Resident Person: As per Article 11 of Federal Decree-Law No. 47 of 2022, a foreign juridical entity is treated as a resident if its place of effective management and control is in the UAE — typically where strategic decisions are made.
• Tax Base:
- A Non-Resident with a PE is taxed on income attributed to that PE and any UAE-sourced income.
- A Foreign resident juridical person recognized as resident is taxed on worldwide income.
Examples:
• A foreign company with a UAE offi...