Can You Run a UK Business from the UAE?

Yes, you can run a UK business from the UAE. UK company law places no restriction on directors living overseas, and many British entrepreneurs continue operating their UK limited companies after relocating to Dubai or elsewhere in the Emirates. The legal position is straightforward. The tax position is not. Once you move, UK corporation tax, UAE corporate tax, residency rules and treaty mechanics begin to interact in ways that require careful structuring from the outset.

For many business owners already based in the UAE long-term, a UAE company structure is the more efficient and practical solution.

Is It Legal for a UAE Resident to Run a UK Company?

The short answer is yes. The Companies Act 2006 imposes no nationality or residency requirement on company directors. Section 155 requires only that a private limited company has at least one director who is a natural person; section 156 sets a minimum age of 16. Neither provision contains any geographic restriction.

A UAE resident can serve as the sole director of a UK limited company without any legal impediment. There is no requirement to appoint a UK-based co-director, no residency threshold to meet, and no Companies House restriction on foreign nationals holding office.

What the registered office rules require

Every UK company must maintain a registered office at an “appropriate address” in England, Wales, Scotland, or Northern Ireland. Since March 2024, PO boxes no longer qualify. In practice, a UAE-based director typically uses a virtual office service, which costs approximately £39–50 per year and satisfies the requirement.

The director’s own service address, which is displayed publicly on the Companies House register, can be anywhere in the world. A UAE address is entirely acceptable, which means the director’s UK residential address (if they have one) can be kept off the public register.

The identity verification requirement coming in 2026

The Economic Crime and Corporate Transparency Act 2023 introduced mandatory identity verification for all UK company directors. By November 2026, all existing directors, including those based overseas, must verify their identity via GOV.UK One Login or through an Authorised Corporate Service Provider. This applies regardless of location and is worth early planning.

Legal permissibility is not the same as commercial or tax efficiency, however. The sections that follow explain why many UAE-based directors eventually conclude that a UAE entity is the more rational long-term structure.

Does a UK Company Pay Corporation Tax If the Director Lives in the UAE?

Yes, unconditionally, and this is where most business owners who relocate to the UAE get their first unpleasant surprise.

Corporation Tax Act 2009, section 14 states that a company incorporated in the United Kingdom is UK tax resident for corporation tax purposes. The statute is absolute. HMRC’s International Manual at INTM120040 confirms the incorporation rule overrides all common law exceptions.

Why incorporation in the UK locks in UK corporation tax

Moving to the UAE as a director does not reduce the company’s UK corporation tax liability by a single penny. The company was incorporated in the UK; it remains UK tax resident regardless of where it is managed from.

UK corporation tax rates currently stand at 19% on profits up to £50,000, 25% on profits above £250,000, with marginal relief applying between those thresholds. These rates apply to the company’s worldwide profits regardless of where its director lives or where work is carried out.

The only route out of this position is treaty non-resident status, a mechanism under the UK-UAE Double Taxation Agreement that is discretionary, multi-year in practice, and triggers exit charges under TCGA 1992, section 185 on transition. When a UK company becomes treaty non-resident, section 185 treats it as having disposed of all its assets at market value at the point of departure, a potentially significant tax event that requires careful planning and is not a step taken lightly.

A UAE entity, by contrast, pays 9% corporate tax on profits above AED 375,000 (approximately £80,000). Below that threshold the rate is 0%. For qualifying free zone companies earning qualifying income, the rate is 0% entirely. This differential becomes commercially significant above roughly £50,000 in annual profit.

What central management and control means for a UAE-based director

Central management and control (CMC) is the highest level of strategic direction over a company. It is distinct from day-to-day operations or where the business physically trades.

The foundational case is De Beers Consolidated Mines v Howe [1906], in which the House of Lords held that a company resides where “central management and control actually abides.” HMRC’s Statement of Practice 1/90, codified at INTM120200, elaborates: where a single individual exercises all CMC, the company resides where that individual operates. This is paragraph 13 of SP1/90, and it has direct consequences for the UAE scenario.

The dual residency problem this creates

If a UK company’s sole director makes all strategic decisions from Dubai, CMC is in the UAE under these principles. This does not override the CTA 2009 incorporation rule. The company remains UK tax resident, but it also means the company is likely also tax resident in the UAE under Article 11(3)(b) of Federal Decree-Law No. 47 of 2022.

Laerstate BV v HMRC [2009] confirmed that a single individual’s location is sufficient to establish CMC where that person exercises genuine control. Development Securities v HMRC [2020] reinforced that courts look at where real decisions are made, not where meetings are formally minuted.

The result is dual corporate tax residency: UK by statute, UAE by effective management. Resolution is possible only through the Double Taxation Agreement’s Mutual Agreement Procedure.

How the UK-UAE Double Taxation Agreement Applies to Your Company

The UK-UAE Double Taxation Convention was signed on 12 April 2016 and entered into force on 25 December 2016. It was the first comprehensive double tax treaty between the two countries.

Article 2 covers UAE corporate tax via a forward-looking clause, meaning the UAE’s 9% corporate tax introduced in June 2023 falls within the treaty’s scope despite not existing when the convention was signed. Article 21 provides for elimination of double taxation: UAE corporate tax paid can be credited against UK corporation tax, and vice versa. This reduces but does not eliminate double taxation exposure.

The tie-breaker rule for dual-resident companies

This is where the treaty creates genuine difficulty. Article 4(4) contains no automatic place of effective management tie-breaker. Unlike most older treaties, the UK-UAE convention requires a Mutual Agreement Procedure. HMRC and the UAE Ministry of Finance must negotiate on a case-by-case basis to determine which country the dual-resident company belongs to.

The Protocol to the convention directs competent authorities to consider where senior management is conducted and where board meetings are held. But the list is not exhaustive, and no timeline is prescribed.

If no agreement is reached, the company is denied most treaty benefits. It cannot claim relief under Articles 7, 10, 11, 12, or 13. In the worst outcome, it faces double taxation in both jurisdictions with no treaty remedy. MAP negotiations routinely take years.

The absence of a clean, automatic tie-breaker is a structural weakness in the treaty. It means dual residency creates genuine and prolonged uncertainty, and it is one of the most common reasons UAE-based business owners establish a UAE entity rather than waiting for a resolution that may never arrive.

Are dividends from a UK company taxable in the UAE?

No, not at the personal level. The UK does not levy withholding tax on dividends paid by UK private limited companies. Dividends are paid gross to shareholders regardless of where they live.

HMRC Helpsheet HS300 classifies dividends from UK companies as “disregarded income” for non-UK residents. The UK tax charge is restricted to tax deducted at source, which for company dividends is nil.

The UAE imposes no personal income tax. Dividends received in the UAE by a UAE-resident individual shareholder are therefore tax-free at the personal level. This position holds only as long as the individual maintains genuine non-UK-resident status under the Statutory Residence Test, which is covered in Section 5.

The tax-free personal position is real and valuable. The caveat is that the company’s profits bear UK corporation tax at up to 25% before any dividend is paid. A UAE free zone structure can reduce that corporate-level charge to 0% on qualifying income. The personal position may look similar on paper, but the pre-dividend tax hit is materially different.

Does a UK Company Create a Tax Liability in the UAE?

This is the question most UK business owners in the UAE never think to ask, and it is increasingly consequential since the UAE introduced corporate tax in June 2023.

UAE Corporate Tax Law, Federal Decree-Law No. 47 of 2022, Article 14 defines permanent establishment broadly. Article 14(2)(a) includes “a place of management where management and commercial decisions that are necessary for the conduct of the Business are, in substance, made.” Where a UAE-based director manages a UK company from a home office or dedicated workspace in Dubai on a regular and continuous basis, this provision may be triggered. The FTA’s guidance requires a degree of permanence and business activity beyond incidental management. Each case turns on its specific facts.

Article 14(1)(b) creates a dependent agent permanent establishment where a person habitually concludes or negotiates contracts on behalf of the company. A sole director who routinely signs contracts from the UAE may meet this test, depending on how regularly and consistently this activity is conducted. The independent agent exemption at Article 14(6) is unlikely to assist. A director acting exclusively for the company is not, by definition, an independent agent.

The position is not automatic, but the risk is real. Many UAE-based directors of UK companies have an unregistered UAE permanent establishment and are unaware of it.

Permanent Establishment vs Full UAE Tax Residence: the Financial Difference

These two outcomes are not the same, and the financial consequences differ significantly. The table below sets out the distinction.

Article 11(3)(b) treats a foreign company as a UAE Resident Person if it is “effectively managed and controlled” in the UAE. The Federal Tax Authority’s published guidance confirms that the determining factor is where “key management and commercial decisions are in substance made.” For a sole UAE-based director managing a UK company, full UAE tax residency is arguable depending on the facts, though this remains a developing area and the FTA has not yet issued definitive guidance equating sole-director CMC with automatic UAE corporate residency for foreign entities.

Either outcome creates UAE tax obligations that most UK business owners do not plan for when they relocate. A UAE entity, properly structured, provides a clean and compliant framework that eliminates this exposure.

FTA registration deadlines and penalties for UK companies with a UAE presence

Article 51 of the Corporate Tax Law requires all Taxable Persons, including Non-Resident Persons with a UAE permanent establishment, to register with the Federal Tax Authority and obtain a Tax Registration Number.

FTA Decision No. 3 of 2024 sets the registration deadlines. For a PE that existed before 1 March 2024, registration was required within 9 months of the PE’s existence. For a PE established on or after 1 March 2024, the deadline is 6 months. For a company treated as effectively managed and controlled in the UAE, registration is required within 3 months of the end of the first financial year.

The penalties are set out in Cabinet Decision No. 75 of 2023: AED 10,000 for late registration, AED 500–1,000 per month for late returns, and 14% annual interest on unpaid tax. The FTA launched a penalty waiver initiative effective 14 April 2025, retroactive to 1 June 2023, waiving the late registration penalty for those who submit their first return within 7 months of their first tax period end.

Registration is mandatory even where no UAE tax is ultimately due. Nil returns must still be filed on time.

What Tax Do You Pay Personally as a UAE-Based Director of a UK Company?

The personal tax position depends entirely on whether you qualify as non-UK-resident under the Statutory Residence Test. If you do, the personal position is largely favourable. If you do not, you face UK income tax on worldwide income, including all salary and dividends from the UK company.

The Statutory Residence Test: Day Count Thresholds That Determine Your UK Tax Status

The SRT was introduced by Finance Act 2013, Schedule 45. HMRC’s official guidance is published in RDR3. The test works in three steps.

The automatic overseas tests are the cleanest route to non-UK residency. If you were UK-resident in any of the three preceding tax years and spend fewer than 16 days in the UK in the current year, you are automatically non-UK-resident. If you were not UK-resident in any of those three years, the threshold rises to 46 days. A third test applies to those working full-time overseas: fewer than 91 UK days, fewer than 31 UK workdays, and no significant break from overseas work.

The sufficient ties test catches those who do not meet an automatic test. Five ties are assessed: family (spouse or minor children in the UK), accommodation (UK accommodation available and used), work (40+ UK workdays), the 90-day tie (90+ UK days in either of the two preceding years), and the country tie (UK has the most midnight-presence days, for previously UK-resident individuals). For someone previously UK-resident, spending 46–90 days in the UK combined with three of these ties is enough to restore UK tax residency.

The risks are practical and easy to underestimate. Maintaining UK accommodation, leaving a family in the UK, or routinely travelling back for business can erode non-resident status quickly. HMRC can and does challenge SRT claims, and day-count records must be meticulous.

UK PAYE on a Director’s Salary: the Cost of Duties Performed in the UK

Directors are treated as office holders under UK law. HMRC Employment Income Manual EIM40004 makes clear that earnings for duties performed entirely outside the UK are not UK-taxable for a non-resident director. This is a genuine advantage of relocating, provided all duties are in fact performed overseas.

The problem arises with UK visits. There is no Short-Term Business Visitor exemption for directors; they are specifically excluded from HMRC’s EP Appendix 4 arrangement. A single board meeting held in the UK triggers PAYE on the earnings attributed to that day. There is no de minimis threshold.

Where only some duties are UK-based, the company can apply to HMRC for a section 690 direction, allowing PAYE to operate only on the estimated proportion of earnings attributable to UK duties. There is no UK-UAE social security agreement. If all duties are performed outside the UK, no Class 1 NIC arises. HMRC does offer an administrative concession for board meetings: no NIC if the director attends a maximum of 10 meetings per year, each lasting no more than two nights.

All board meetings should be held remotely wherever possible. Records of where every professional duty is performed are not optional.

UK Dividends Received in the UAE

No UK withholding tax applies to dividends from UK private limited companies. HMRC Helpsheet HS300 classifies these dividends as disregarded income for non-UK residents, meaning the UK tax charge is nil.

The UAE imposes no personal income tax. Dividends received in the UAE by a genuine non-UK-resident individual are tax-free. This position collapses entirely if the individual fails to maintain non-UK-resident status under the SRT, which is why day-count discipline is not an administrative formality but a financial necessity.

Banking, VAT, and Companies House: the Operational Burden of a UK Company Managed From the UAE

Running a UK company from the UAE is legally permissible. Running it efficiently and compliantly from overseas is harder than most people anticipate.

Which UK banks accept non-resident directors

There is no legal prohibition on non-resident directors holding UK business bank accounts. The practical barrier is Anti-Money Laundering regulation, which requires banks to verify the identity and address of all directors and beneficial owners.

High-street banks such as Lloyds, NatWest, and Monzo typically require at least one UK-resident director or an in-person visit to a UK branch. HSBC accepts non-resident directors but generally requires an in-person appointment. Fintech options including Tide, Wise Business, and Revolut Business are accessible online to non-residents, though Electronic Money Institutions do not offer the same FSCS deposit protection as fully licensed banks.

Banking friction is one of the most consistently reported frustrations among UAE-based directors of UK companies. A UAE business bank account, opened as part of the company registration process, is typically straightforward and operates in multiple currencies including GBP.

VAT Registration for a UK Company Managed From the UAE

HMRC VAT Notice 700/1 provides that a UK company with only a virtual registered office may be classified as a Non-Established Taxable Person (NETP), and the consequences of that classification are significant.

NETPs cannot use the £90,000 VAT registration threshold. They must register for UK VAT from the moment they make the first taxable supply of any value in the UK. HMRC may also require the company to appoint a UK-based VAT representative who shares personal liability for VAT debts.

Whether a company qualifies as “established” is fact-specific. A virtual office address alone is not sufficient. HMRC requires evidence of genuine business operations at that address. This classification should be considered before the first taxable UK supply is made, not after.

Companies House filing deadlines that apply regardless of where you live

Every UK company director remains subject to the full suite of Companies House obligations regardless of their location.

The confirmation statement must be filed at least once every 12 months, within 14 days of the end of the review period. The online filing fee is £50. Annual accounts must be filed within 9 months of the accounting reference date. Late filing attracts automatic penalties: £150 for accounts up to one month late, rising to £1,500 for accounts more than six months late. These penalties double if accounts are late in two consecutive financial years.

The PSC register must be updated within 14 days of any change. PSC identity verification became mandatory from November 2025. Changes to directors, the registered office, or share capital must be notified within 14 days. Non-compliance is a criminal offence, not merely a civil penalty.

These deadlines do not pause because the director is in a different time zone. UAE-based directors who do not have active UK-based accounting support miss them with uncomfortable regularity.

Which UAE Visa Allows You to Run a UK Company Without Risk

Not all UAE visas are equal when it comes to directing a foreign company, and operating on the wrong one creates compliance risk that most people overlook.

Employment visa restrictions

Federal Decree-Law No. 33 of 2021, Article 6 authorises an employment visa holder to work only for their sponsoring employer. Directing a UK company, even remotely and informally, could be characterised as unauthorised work activity. Doing so requires a MOHRE part-time work permit and a No Objection Certificate from the current sponsor. Discovery of unauthorised commercial activity can result in visa cancellation, deportation, and fines. The risk is low but not theoretical.

The right visa types for UK company directors

An investor or partner visa is self-sponsored and carries no restriction on directing a foreign company. There is no employment exclusivity requirement.

The Golden Visa provides 10-year self-sponsored UAE residency with no employment restrictions. It also permits extended periods outside the UAE without losing visa validity, which is a significant advantage for those who travel regularly to the UK for business. For a UAE-based director of a UK company, the Golden Visa is the most appropriate and most secure foundation.

The MOHRE freelance work permit is issued for independent self-employed activity and is consistent with directing a foreign company. The remote work visa is designed for offshore employees earning at least USD 3,500 per month from an overseas employer, though it is structured for employees rather than directors or shareholders.

Why the UAE Tax Residency Certificate Matters

A UAE Tax Residency Certificate requires spending 183 or more days in the UAE within a 12-month period. The certificate is used to claim benefits under the UK-UAE Double Taxation Agreement and to formally establish UAE personal tax residency status. Without it, an individual claiming non-UK-resident status has a weaker evidentiary position if HMRC challenges their SRT claim.

UK Company vs UAE Company: Which Structure Makes More Financial Sense

For business owners who are genuinely, long-term UAE-based, a UAE company structure is almost always the more commercially rational choice. The UK company structure remains justified in specific, defined circumstances.

When keeping a UK company is justified

If the majority of your clients are UK-based and contractually require a UK-registered supplier, maintaining the UK entity is not just sensible. It may be commercially necessary. The same applies where UK VAT registration is needed for input VAT recovery on UK expenditure, or where the UK Patent Box regime is relevant to the business (which provides a 10% effective rate on qualifying patent income).

At lower profit levels, UK running costs are materially cheaper than UAE equivalents. A UK limited company costs approximately £1,000–2,500 per year to maintain in accounting and compliance costs. If annual profits sit below around £50,000, the tax saving from a UAE structure may not offset the higher cost of establishing and maintaining one.

Short-term UAE relocation, with a confirmed plan to return within two to three years, is also a reasonable basis for retaining a UK structure rather than restructuring around a temporary move.

When a UAE company delivers a better commercial outcome

Where the majority of revenue is UAE or GCC-based, or invoiced in AED, a UAE entity is the natural commercial home for the business. Where the director’s UAE residency is long-term or permanent, there is little justification for carrying the structural inefficiency of UK corporation tax at 19–25%.

The numbers become compelling at higher profit levels. The table below models the corporate tax position on £200,000 of profit under each structure (using an approximate GBP/AED exchange rate of 4.6).

Annual UAE running costs of approximately £5,500–13,000 are absorbed comfortably within the first year of either differential. At £200,000 profit, the free zone structure generates a saving of roughly £34,500–42,000 net of running costs.

For activity that qualifies for free zone 0% corporate tax on qualifying income, including manufacturing, commodities trading, logistics, and fund management, the comparison becomes even starker. Small Business Relief, which applies a 0% rate to entities with revenue below AED 3 million, is available until 31 December 2026, extending the benefit further for early-stage businesses.

UAE company formation also provides local banking, local contracting capability, and the ability to sponsor employee and investor visas. These are operational tools the UK structure cannot offer.

When running both a UK and UAE company makes sense

A dual structure of UK Ltd for UK-facing activity and a UAE entity for UAE and GCC revenue is common among entrepreneurs who have built client relationships in both markets and do not want to sacrifice either.

Inter-company arrangements between the two entities must comply with transfer pricing rules under both UK and UAE law, and with Article 9 of the UK-UAE DTA. Each entity must have genuine commercial substance: real activity, real contracts, real banking. It cannot simply be a holding shell designed to shift income between jurisdictions.

A dual structure is more complex to administer than either entity alone. But it eliminates the core risk of running UK-facing operations through a UAE entity (where UK clients may object) or UAE-facing operations through a UK company (where UAE corporate tax exposure arises through the permanent establishment rules).

The Seven Compliance Failures That Create the Most Exposure

Most of the serious problems that arise for UAE-based directors of UK companies are not the result of deliberate avoidance. They result from assumptions that turn out to be wrong.

First: assuming relocation removes UK corporation tax. Corporation Tax Act 2009, section 14 makes this impossible. The company was incorporated in the UK; it remains UK tax resident. The director’s address is irrelevant.

Second: failing to register with the UAE FTA. A UK company managed from the UAE may have a UAE permanent establishment or may qualify as effectively managed and controlled in the UAE, depending on the facts and degree of management activity. Where that threshold is crossed, failure to register carries an AED 10,000 penalty, plus AED 500–1,000 per month in ongoing late-return charges and 14% annual interest on unpaid tax.

Third: operating on a UAE employment visa without appropriate authorisation. Employment visa holders are authorised to work only for their sponsoring employer. Directing a UK company is not covered by that authorisation without a MOHRE permit and an NOC.

Fourth: failing the Statutory Residence Test through insufficient attention to UK day counts. For a previously UK-resident individual, spending 46 days in the UK combined with three sufficient ties is enough to restore UK tax residency, and with it UK income tax on worldwide income. Many people do not realise how easily this threshold is reached.

Fifth: performing duties in the UK without managing PAYE obligations. There is no de minimis threshold for PAYE on directors. A single board meeting held in the UK triggers a PAYE liability on earnings attributed to that day.

Sixth: failing to identify Non-Established Taxable Person status before making the first taxable supply in the UK. NETPs must register for UK VAT from the first taxable supply of any value. The £90,000 threshold does not apply. This is routinely discovered late, after HMRC has already identified the issue.

Seventh: missing Companies House deadlines through lack of UK administrative support. Late accounts penalties are automatic, start at £150, and double if late in two consecutive years. There is no warning, no discretion, and no appeal on the basis of being based overseas.

The Right Structure Depends on Where Your Business Actually Operates

Running a UK business from the UAE is legal, but the efficient structure is rarely automatic. UK corporation tax still applies to a UK-incorporated company, and UAE corporate tax obligations can arise at the same time through permanent establishment or effective management rules. While the UK–UAE treaty can help, it is not a quick or guaranteed fix.

If you are genuinely UAE-based long term, a UAE company, or a UK–UAE dual structure, often delivers a cleaner tax position, stronger banking access, and the ability to sponsor visas and contract locally. The key is to choose the structure before HMRC enquiries or FTA penalties force the decision.

If you want a clear answer for your specific setup, Virtuzone can map the right structure, handle UAE licensing and visas, and coordinate with your UK tax advisers so the plan works in practice. Speak to Virtuzone to book a structured consultation and get this right from the outset.

FAQs

Can a non-UK resident be the sole director of a UK limited company?

Yes. The Companies Act 2006 imposes no nationality or residency requirement on directors. A UAE resident can serve as the sole director of a UK private limited company without restriction. The company must still maintain a registered office at an appropriate address in the UK.

Does my UK company create a permanent establishment in the UAE?

Possibly, depending on the facts. UAE Corporate Tax Law, Article 14 includes a place of management as a fixed-place permanent establishment, but requires a degree of permanence and regularity. Where a UAE-based sole director manages the company continuously from a fixed location, the fixed-place PE test is likely engaged. Article 14(1)(b) may create an additional dependent agent PE where contracts are habitually concluded from the UAE. Each case is fact-specific and specialist advice is recommended.

Do I need to register my UK company for UAE corporate tax?

If your UK company has a UAE permanent establishment or is effectively managed and controlled in the UAE, yes. FTA Decision No. 3 of 2024 sets the registration deadlines, and Cabinet Decision No. 75 of 2023 imposes an AED 10,000 penalty for late registration. Registration is required even where no UAE tax is ultimately due.

What happens if I do not register my UK company’s UAE permanent establishment with the FTA?

Late registration incurs an AED 10,000 penalty. Late returns carry AED 500-1,000 per month in penalties, and unpaid tax accrues interest at 14% per annum. The FTA’s penalty waiver initiative, effective April 2025, waives the registration penalty for those who file their first return within 7 months of their first tax period end.

What is the best UAE visa type for someone running a UK company?

The Golden Visa and investor or partner visa are the most appropriate. Both are self-sponsored and carry no restriction on directing a foreign company. The employment visa restricts the holder to working only for the sponsoring employer, which creates compliance risk.

Can I open a UK business bank account if I live in the UAE?

There is no legal prohibition, but AML regulations make it difficult in practice. Most high-street banks require a UK-resident director or an in-person visit. Fintech options such as Tide, Wise Business, and Revolut Business are more accessible to non-residents.

How many days can I spend in the UK without becoming UK tax resident again?

It depends on your history and ties. Under the Statutory Residence Test, a previously UK-resident individual with three sufficient ties becomes UK tax resident again by spending just 46 days in the UK in a tax year. The threshold rises to 16 days if four ties are present. Meticulous day-count records are essential.

Is it better to set up a company in Dubai or keep my UK company?

For long-term UAE residents with UAE or internationally-facing revenue, a UAE company is almost always more efficient. UAE corporate tax is 9% versus up to 25% in the UK, with a 0% rate available for qualifying free zone income. For those with predominantly UK clients or short-term UAE plans, retaining the UK structure is often more practical.

Can I run both a UK company and a UAE company at the same time?

Yes. A dual structure of UK Ltd for UK-facing clients and a UAE entity for UAE and GCC activity is common and commercially rational. Each entity must have genuine commercial substance, and inter-company arrangements must comply with transfer pricing rules under both jurisdictions and Article 9 of the UK-UAE DTA.