UAE is excluded from the list of offshore jurisdictions: new tax rules in 2026

In November of 2025 Russian Ministry of Finance published draft orders according to which the United Arab Emirates are excluded from all lists of offshore jurisdictions from January 1, 2026. This opens up a number of new tax opportunities for businesses but some restrictions will still remain for holding companies.

What new business opportunities will appear?

• Zero tax rate on dividends from the UAE: Russian companies will now be able to get dividends from affiliated companies in UAE at 0% rate, provided that ownership share is at least 50% and the assets have been owned for no less than a year. Note: dividends must be paid out of the profit that has already been taxed in UAE.
• Benefits for the sale of shares and transfer of property. A 0% tax is applied on the sale of shares of Emirati companies (subject to additional conditions). It is also permitted to use benefits for the gratuitous transfer of property within the group.

What kind of restrictions remain for holdings?

• A new requirement for the release of profits of a controlled foreign company (hereinafter – CFC): in order not to tax the profits of their companies in foreign jurisdictions, the corporate tax rate in the country of registration of the CFC must be at least 15%. Since the general corporate tax rate in the UAE is set at 9%, it does not seem possible to fulfill this condition. Consequently, the profits of CFC registered in the UAE are subject to inclusion in the tax base of their Russian controlling entities.
• Control under the transfer price formation (hereinafter referred to as TPF) remains: transactions with independent counterparties from countries where the tax rate is 15% or lower (as it is in the UAE) will continue to be recognized as controlled for TPF purposes. Exclusion from offshore lists does not cancel the preparation of TPF documentation.

What does SCHNEIDER GROUP recommend?

• Conducting an audit of the structure: evaluate which companies / chains are subject to the new rules.
• Recalculating the tax consequences: examine where and how the 0% dividend rate can be applied, and how the new restrictions will influence the profits of the CFC.
• Preparing documents beforehand: confirm the ownership structure, tax base and income / expenses status.