France–United Arab Emirates (Dubai) cluster
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France–UAE taxation: the France–United Arab Emirates treaty in practice

The tax relationship between France and the United Arab Emirates rests on a long-standing bilateral treaty, supplemented by an amending protocol, and on an Emirati environment with zero personal taxation. Read correctly, this treaty protects against double taxation; poorly mastered, it leaves full French taxation in place on many types of income. The firm, admitted to the Paris and Geneva Bars, sets out its mechanics here article by article.

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Analysis based on primary sources (Légifrance, BOFiP, impots.gouv.fr) as of 1 July 2026. The numbering of treaty articles is indicated subject to verification against the official text.
— In brief
Treaty
Signed on 19 July 1989, in force on 1 July 1990, supplemented by the amending protocol of 6 December 1993 (in force on 1 June 1995).
Scope
Personal income tax, corporate income tax, transfer duties on gratuitous transfers (inheritance and gifts) and wealth tax (now the IFI).
Emirati taxation
0% personal income tax; 9% corporate tax above AED 375,000 since 1 June 2023; 5% VAT.
Key point
French real estate and real estate capital gains remain taxable in France; as the Emirati tax credit is nil, French taxation is effective.
Reference
Administrative doctrine: BOI-INT-CVB-ARE.
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Essential benchmarks of the treaty

The France–United Arab Emirates tax treaty was signed in Abu Dhabi on 19 July 1989 and published in France by Decree no. 90-631 of 13 July 1990. It entered into force on 1 July 1990. An amending protocol of 6 December 1993, in force on 1 June 1995, notably abolished the 5% withholding tax on certain interest and extended certain protections.

Unlike many recent treaties, this text covers a broad material scope: personal income tax, corporate income tax, but also transfer duties on gratuitous transfers (inheritance and gifts) and wealth tax, today the IFI. The reference French administrative doctrine appears in the BOFiP under the identifier BOI-INT-CVB-ARE.

The benchmarks below set the framework before turning to the category-by-category allocation.

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Issues and obligations

Treaty residence: the key to everything

Where an individual is resident in both States, the treaty resolves the question through a series of ranked criteria (Article 4). The order is as follows: first, the permanent home; failing that, the centre of vital interests, that is, the place of the closest personal and economic ties; then habitual abode; and, as a last resort, nationality. This cascade is decisive. A person settled in the UAE but who keeps their family home, the bulk of their income or the seat of their business in France may be reclassified as a French resident within the meaning of the treaty. French domestic law (Article 4 B of the CGI) moreover applies alternative criteria — home or main place of stay, professional activity, centre of economic interests — any one of which is enough to establish domicile in France. The treaty prevails over domestic law, but it only applies where there is a genuine and demonstrable Emirati residence. The firm systematically assesses, upstream, the strength of the connection to the UAE before reasoning about the allocation of taxing rights.

Allocation by category of income

Dividends and interest are, under the treaty, taxable in the beneficiary's State of residence; the 1993 amending protocol abolished the 5% withholding that applied to certain interest. In practice, for French-source dividends paid to an Emirati resident, France frequently applies a withholding tax, with the treaty exemption obtained through refund upon proof of residence and beneficial-owner status. Real estate capital gains remain taxable in the State where the property is situated: a French asset remains taxed in France. Capital gains on securities in principle fall to the transferor's State of residence, subject to companies predominantly holding real estate. Salaries follow the place where the activity is carried out, with the classic 183-day clause; pensions are in principle taxed in the State of residence, with social-security pensions remaining taxable in the paying State. Elimination of double taxation operates through the tax credit method (Article 19). Yet, since Emirati personal taxation is nil, the creditable amount is often nil too: for French-source rental income or a French-source real estate capital gain, the mechanism results in full French taxation. The Emirati advantage applies to income for which the treaty reserves taxation to the State of residence, not to income that is French by nature.

Wealth, IFI and transmission

The treaty covers wealth tax, which has direct consequences for the IFI of Emirati residents holding real estate in France. The treatment must be checked asset by asset, since French real estate remains at the heart of the French taxable base. The text also applies to transfer duties on gratuitous transfers — inheritance and gifts — for deaths occurring on or after 1 July 1990. The allocation of taxing rights between France and the UAE must be established article by article, taking account of the location of the assets and the residence of the deceased or the donor. On these wealth matters, a superficial reading of the treaty frequently leads to errors. The firm, present in Paris and Geneva, combines the treaty analysis with estate planning and ownership structuring, in order to avoid both double taxation and reclassifications.

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Lead counsel — Me Jonathan Bensaid

Me Jonathan Bensaid, founding partner, advises UHNWIs, family offices, executives and non-residents on international wealth taxation and cross-border compliance. The firm is admitted to the Paris & Geneva Bars.

  • tax treaty
  • France-UAE
  • Dubai
  • IFI
  • real estate capital gains
  • non-residents
  • double taxation
— Frequently asked questions

A protective treaty, provided its mechanics are mastered

Does the France–UAE treaty exempt my French rental income from tax?

No. French-source rental income and real estate capital gains remain taxable in France, the State where the property is situated. As the Emirati tax credit is nil, French taxation is effective.

Since when has the treaty been in force?

The treaty, signed on 19 July 1989, entered into force on 1 July 1990. An amending protocol of 6 December 1993 has applied since 1 June 1995.

Are French dividends paid to a Dubai resident exempt?

The treaty reserves taxation to the State of residence, but France applies a withholding tax in practice. The treaty exemption is obtained through refund, upon proof of residence and beneficial-owner status.

Does the treaty cover inheritance and the IFI?

Yes. Its scope includes transfer duties on gratuitous transfers (inheritance and gifts) and wealth tax, today the IFI. The treatment depends on the location of the assets and the residence.

Is living in Dubai enough to stop being a French tax resident?

No. The treaty only applies where there is a genuine and demonstrable Emirati residence. Keeping your home, your income or the centre of your economic interests in France may maintain French tax residence.

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Securing a France–UAE situation

The France–UAE treaty is a powerful but demanding tool: its real scope depends on the strength of the residence and the nature of each type of income. The firm Bensaid Avocats, admitted to the Paris and Geneva Bars, assists executives, families and investors in reading this treaty and structuring their wealth between France and the UAE. An initial discussion allows us to map out the risks and levers specific to your situation.

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This page presents a general analysis as of 1 July 2026 and does not constitute personalised tax advice. The numbering of treaty articles is mentioned subject to verification against the official text. Every situation calls for an individual review by a lawyer.