Permanent Establishment Advisory
A fixed office, a project site or a person signing contracts for you can create a permanent establishment, which means the profits linked to it are taxable there. We assess the risk before it turns into a tax bill.
- Corporate Tax Law, Art. 14Legal basis
- Fixed place, agent, long projectsTriggers
- Inbound and outboundApplies
How it works in the UAE
For foreign companies, a permanent establishment in the UAE brings UAE corporate tax registration and filing. For UAE companies, staff or agents working abroad can create a PE in another country with its own tax and filing rules.
The tests come from the UAE Corporate Tax Law and the relevant double tax agreement, and they look at what actually happens on the ground: where decisions are made, who signs contracts and how long people stay. We review those facts and recommend how to organise activity to stay on the right side of the line.
What the service includes
PE risk assessment
Review of offices, staff, agents and projects against the PE tests.
Business structure review
Whether a branch, subsidiary or contract model suits you best.
Cross border tax advisory
Tax consequences in the UAE and the other country.
DTAA and treaty analysis
Treaty definitions that can narrow or widen PE exposure.
PE compliance support
Registration, profit attribution and filing where a PE exists.
Ongoing advisory services
Monitoring as projects, staff and contracts change.
Who it is for
- Foreign companies with staff or projects in the UAE
- UAE companies sending employees abroad
- Businesses using agents or distributors in other markets
- Remote teams spread across countries
How we work with you
Assessment
We gather the facts on people, places and contracts.
Risk identification
Each activity is tested against UAE law and the treaty.
Recommendations
You get clear options to reduce or manage PE risk.
Support
We help register and file where a PE is unavoidable.
Documents we usually need
- Group structure chart
- Employment and secondment contracts
- Agency and distribution agreements
- Details of projects, sites and durations
- Office leases
We confirm the exact list after a short review, as requirements vary by authority and case.
Key corporate tax rules
| Rule | Detail |
|---|---|
| Rates | 0% on taxable income up to AED 375,000, 9% above. Qualifying Free Zone Persons: 0% on qualifying income, 9% on the rest. |
| Registration deadline | Companies incorporated on or after 1 March 2024 must register within 3 months of incorporation. |
| Return and payment | Within 9 months of the end of the tax period. |
| Small Business Relief | Revenue of AED 3,000,000 or less, for tax periods ending on or before 31 December 2029. |
| Audited accounts | Required where revenue exceeds AED 50 million, and for all Qualifying Free Zone Persons. |
| Large groups | Multinational groups with revenue of EUR 750 million or more are subject to a 15% domestic minimum top up tax from 2025. |
| Late registration | AED 10,000. Waived if the first return is filed within 7 months of the first tax period end. |
| Late filing | AED 500 a month for the first 12 months, then AED 1,000 a month. |
Sources: Federal Decree Law No. 47 of 2022; Cabinet Decision No. 116 of 2022; FTA Decision No. 3 of 2024; Ministerial Decisions No. 73 of 2023, No. 82 of 2023 and No. 131 of 2026; Cabinet Decision No. 75 of 2023. Checked November 2026. Rules change, so we confirm the position for your case.
Questions we hear often
What creates a permanent establishment in the UAE?
Generally a fixed place of business through which the foreign company carries on business, or a person in the UAE who habitually concludes contracts on its behalf. Construction and installation projects can also qualify after a period of time.
Does working from home in the UAE create a PE?
It can. The UAE has issued guidance on temporary and home based work, and the answer depends on the role, the duration and whether the person concludes contracts.
What happens if a PE exists?
The foreign company must register for UAE corporate tax and pay tax on profits attributable to the PE.
Can a treaty help?
Yes. Many treaties set higher thresholds for project PEs and exclude preparatory or auxiliary activities.
Related services
Get a fixed quote for permanent establishment (pe) advisory
Tell us a little about your business. We will reply within one business day with what is needed, the timeline and a fixed fee.
- Straight answers from qualified accountants and tax agents
- Fixed fees agreed before we start
- Office in Al Fahidi, Dubai, and support across the UAE
An adviser will be in touch shortly. For anything urgent, message us on WhatsApp or call +971 56 505 9557.