Nová Smlouva o zamezení dvojímu zdanění se Spojenými arabskými emiráty

New Double Taxation Treaty with the United Arab Emirates

The Double Taxation Treaty between the Czech Republic and the United Arab Emirates (UAE) entered into force on 13 May 2024. The original Treaty No. 276/1997 Coll. will cease to be in force and will cease to be implemented on 1 January 2025.

From 1 January 2025, the provisions of the new treaty will be implemented in respect of income subject to withholding tax at source paid or credited on or after that date. For other income, the new treaty will apply to income for each taxable period beginning on or after 1 January 2025.

An important new feature is, for example, the change in the definition of resident in Article 4, which will no longer be linked to de facto taxation in the UAE by reason of domicile, permanent residence, place of management or any other similar criterion in the UAE, but will be based on a definition of resident based on local law. This change will thus greatly expand the treaty options for taxpayers with ties to both countries.

Therefore, if your personal situation or your business is connected to the UAE, we recommend you to analyse in detail the impact of each article of the new treaty. If necessary, please contact your preferred advisor or the authors of this article.

Authors:

Michaela Felcmanová

Jana Vodehnalová