Russia has formally removed the United Arab Emirates from its list of offshore jurisdictions. This regulatory change clears the way for the UAE–Russia Double Taxation Agreement (DTAA) to take effect on 1 January 2026.
The agreement will shape how income is taxed for individuals and businesses with links to both countries and will provide clearer rules for cross-border income such as dividends, services, interest, royalties, and investments.
To benefit from the treaty, residents must hold a valid UAE Tax Residency Certificate (TRC). For DTAA purposes, the requirement is specific. a minimum of 180 days of physical presence in the UAE within the calendar year.
The commonly referenced 90-day rule does not apply to international treaty claims and is not accepted by foreign tax authorities, including Russia.
TRC Requirements and Supporting Documents
Applicants must submit:
UAE residence visa
Emirates ID
Proof of income in the UAE such as a salary certificate or trade licence
Proof of address through Ejari or a property title deed
Six months of validated UAE bank statements
GDRFA or ICA movement report showing at least 180 days in the UAE
The Federal Tax Authority reviews each application to verify consistency, substance, and genuine residency.
What the Double Taxation Agreement (DTAA) Means for Individuals and Businesses
Once effective, the treaty will:
Prevent double taxation on eligible income streams
Provide improved certainty for UAE residents earning income from Russia
Strengthen UAE holding and operating structures with Russian exposure
Support cleaner cross-border tax planning and documentation
Those relying on the agreement should confirm their residency position and documentation well ahead of the 2026 activation date.
ACCLRT’s Advisory Support
ACCLRT assists clients with:
Assessing eligibility for the 180-day TRC
Reviewing documentation and residency history
Preparing and submitting TRC applications to the Federal Tax Authority
Advising on treaty positioning and compliant structuring for UAE–Russia income flows
This ensures clients meet the required standards when the DTAA becomes fully operational.
