The France-United Arab Emirates tax treaty, point by point

The tax treaty between France and the United Arab Emirates was signed in Abu Dhabi on July 19, 1989. It allocates between the two states the right to tax each category of income. For dividends, debt income, capital gains excluding real estate, and private pensions, the general rule (first or second paragraph of each article) assigns taxation to the state of residence of the recipient of the income. Exceptions exist in the other paragraphs. An amendment, in force since June 1, 1995, supplemented the treaty, and it is included in the list of treaties modified by the Multilateral Tax Convention (MLI).

A 1989 text, an addendum, the MLI

The agreement dates from July 19, 1989. An amendment was signed on December 6, 1993 and it came into force on June 1, 1995. This amendment created Article 16 A, devoted to wealth.

The administration's commentary bears the reference BOI-INT-CVB-ARE. Its publication began on September 12, 2012, with no end date displayed.

The administrative list of conventions amended by the Multilateral Convention (MLI) includes the United Arab Emirates (BOI-ANNX-000511, dated April 29, 2026). This page does not detail the effective dates or the resulting modifications for your specific situation; these must be examined on a case-by-case basis.

The consolidated text published by the administration clarifies that it does not replace the official texts. For a decision, read the relevant article in its entirety.

Income-based rules

The taxes in question

For France, the convention covers income tax, corporation tax, wealth tax applicable to individuals and inheritance tax, with withholding taxes, advance payments and prepayments.

For the Emirates, it targets all corporate income taxes, as well as all global income, wealth and inheritance taxes, established by the federal state or by the emirates and similar to those targeted for France.

Who is a resident?

Article 4 § 1 defines the resident of each State.

• Resident of France: any person subject to tax in France under French law.
• Resident of the Emirates: any person domiciled, established or having their place of management in the Emirates.

If you are a resident of both States, Article 4, paragraph 2(a), first determines your status based on your permanent home: you are considered a resident of the State where you have such a home. The following criteria are listed in the text, in the order it specifies.

French tax residence is another concept, discussed on our page about leaving France.

Dividends and debt income

Paragraph 1 of Article 8 establishes the principle: dividends paid by a company resident in one State to a resident of the other State are taxable only in that other State, if that resident is the beneficial owner.

Article 9 applies the same principle to income from receivables. It bears this title, not "interest": look for it under that name.

Only paragraph 1 of each article is presented here. The following paragraphs should be read before making any decision.

Capital gains

For capital gains on assets other than real estate, paragraph 2 of Article 11 provides, in principle, for taxation exclusively in the State of which the transferor is resident. The other paragraphs of the article provide for exceptions: these must be read before any transaction.

For real estate, Article 11 § 1 sets out a specific rule. We will not detail it here: it can be found in the text for each transaction.

Wages and the 183-day rule

Article 13 § 1 refers to the State of residence: the salaries of a resident of a State are taxable only in that State, unless the employment is carried out in the other State.

Paragraph 2 provides an exception based on duration: the stay in the other State may not exceed 183 days in total during the tax year in question. The count of days is not sufficient in isolation; the full text of the article must be examined.

This 183-day threshold is not that of Emirati tax residency. It comes from a different text and is assessed over a different period.

Private guesthouses

Article 14 § 1 assigns taxation to the State of residence: pensions paid to a resident of a State in respect of previous employment are taxable only in that State, subject to Article 15. Article 15 is not dealt with here.

Successions

For real estate, Article 17 § 1 stipulates that inheritance tax applies only in the state where the property is located. For movable property, the rule is determined on a case-by-case basis; we will not define it here.

Fortune: Article 16 A

Article 16 A was created by the 1993 amendment. The administrative commentary indicates that residents of the Emirates can benefit from an exemption from wealth tax on their properties located in France when their value is less than that of their movable assets held in France (listed shares, listed receivables).

The convention concerns the wealth tax. This page does not address the application of these rules to the IFI (French real estate wealth tax): this point is examined on a case-by-case basis.

What this page does not cover

The method for eliminating double taxation when both states can tax is not detailed here. Pensions covered by Article 15, the following paragraphs of Articles 8 and 9, and the capital gains tax regime for real estate are addressed in the text.

Numerical example (fictitious profile)

Situation. A French employee, a fictitious profile, residing in the Emirates, is employed by an Emirati company. He undertakes three missions to France during the year: 62, 45 and 38 days.

Issue. He wonders which state can tax remuneration for days worked in France. The basic rule in Article 13, paragraph 1, refers to the state of residence, unless the employment is carried out in the other state. The exception in paragraph 2 is based on the length of stay.

Strategy. He keeps a day-by-day record of the fiscal year in question, before having the other conditions of the text examined.

Result. His three missions total 145 days: the 183-day duration requirement is met, with a 38-day margin. A fourth mission of 45 days would bring the total to 190 days: the duration requirement would no longer be met, with a 7-day overrun. The method for calculating days and other conditions remain to be verified in the text.

What changes depending on your situation

• Your residence as defined in the convention, which depends on your permanent home.
• The nature of the income: dividend, debt income, capital gain, salary, pension.
• The location where the job is performed, and the number of days spent in each state.
• The nature and location of your assets: real estate or personal property.
• The effects of MLI on your situation.

An article should be read in light of the facts in your case, and no result is guaranteed in advance.