October 4, 2026

Double Taxation Agreement (DTA) Between Switzerland and the UAE

Switzerland and the United Arab Emirates concluded an agreement for the avoidance of double taxation in Dubai on 6 October 2011. It entered into force on 21 October 2012 and has applied since 1 January 2013. For Swiss nationals moving to the UAE, this is a considerably more favourable starting point than for Germans or Austrians.

Why the Swiss situation is better

Three countries, three different starting points: Germany has had no treaty at all since the end of 2021. Austria has one, but switched from exemption to credit in 2023. Switzerland has a treaty and continues to apply the exemption method in principle.

Country	Treaty	Method
Germany	none since the end of 2021	national law only
Austria	since 2005, revised 2023	Credit
Switzerland	applicable since 2013	exemption in principle

That is the key difference. Income whose taxation the treaty allocates to the Emirates is excluded by Switzerland from its own taxation, usually subject to progression.

Exemption with progression

Exempt does not mean without consequences. Switzerland may take the exempt income into account when determining the tax rate applied to the remaining income.

For people who move to the Emirates completely and no longer have any taxable income in Switzerland, this reservation has no effect. It becomes relevant as long as Swiss income remains, for example from a property or continuing gainful employment.

Dividends: the exception to exemption

A separate rule applies to dividends. If a person resident in Switzerland receives dividends that may be taxed in the Emirates under the treaty, Switzerland grants relief on application. This consists, at the taxpayer's choice, of a credit for the tax levied there or a partial exemption.

For Swiss companies receiving dividends from a company in the Emirates, the following also applies: they receive the same benefits they would be entitled to if the distributing company were resident in Switzerland. For holding structures, this is the most important sentence in the entire treaty in practice.

How residence is determined

As is usual in treaties, this one also contains an order of priority for cases in which both states treat a person as resident:

Permanent home in one of the two states
If there is a home in both: centre of vital interests
Then habitual abode
Finally, nationality
If still unresolved: mutual agreement procedure between both administrations

This order of priority is the practical advantage over the German situation. Where Germany and the Emirates have no common rule in the event of a dispute, there is one here, and a procedure that resolves it.

The other allocation rules

Immovable property: taxed in the state where the property is located. A Swiss property remains taxable in Switzerland, even if you live in Dubai
Business profits: taxed in the state of residence, unless there is a permanent establishment in the other state
Employment income: generally taxed where the work is performed
Exchange of information: governed by the OECD standard

The former special agreement on the taxation of international air transport enterprises from 1992 was terminated with effect from 1 January 2013 and has been incorporated into the current treaty.

What UAE Corporate Tax has changed

Since June 2023, the Emirates have levied Corporate Tax of 9% on profits above AED 375,000. This means that, for the first time, a tax arises at company level that plays any role at all under the treaty.

For free zone companies with Qualifying Free Zone Person status, the rate remains 0% on qualifying income. If you use this structure, you should have the conditions reviewed annually: substance on the ground, qualifying income, transfer pricing documentation.

The certificate of residence

If you rely on the treaty vis-à-vis the Swiss tax administration, you need proof of residence in the Emirates. The usual document for this is the Tax Residency Certificate issued by the Federal Tax Authority.

It requires a minimum period of stay and a home in the UAE. It is therefore not a form you obtain on the side, but proof of an actual centre of life. And that is exactly how it is examined.

How we assess it

In this constellation, Swiss clients have the most comfortable starting position of the three DACH countries. An existing treaty, the exemption method, a clear order of priority for residence and a mutual agreement procedure: that is a framework you can plan with.

What it does not mean is that moving away is a formality. Here too, your actual centre of life decides, not the visa. The cantonal tax administrations examine deregistrations carefully, and if you keep a property, family or gainful employment in Switzerland, you remain on their radar.

Our advice from client work: before the move, clarify with your Swiss fiduciary (Treuhänder) or tax adviser which income will remain in Switzerland after you leave and how it will be treated. We build and document the UAE side: licence, bank account, Emirates ID and the evidence required for the certificate of residence.