"I have a company in Dubai, a resident visa, I no longer pay anything in Romania." It is the sentence that opens most international-tax consultations, year after year. Usually a list of facts that contradicts it follows — and since 2023, even the Emirati side of the story has changed: the UAE is no longer a jurisdiction with no corporate tax.
The spouse and children live in Brașov, the apartment here is unlet and available at any time, the clients are European, the invoices are issued from a laptop on Strada Lungă, and the person in question spends three or four weeks a year in the UAE. The structure is real from a legal standpoint — the company exists, the licence is valid, the visa is issued. The intended tax effect, however, does not follow.
And since 2023, the Emirates are no longer a jurisdiction "with no corporate tax". The discussion is worth starting from what remains legal in international structures, not from a promise made on a terrace.
Through Federal Decree-Law no. 47/2022, the United Arab Emirates introduced a federal corporate income tax, applicable to financial years beginning on or after 1 June 2023. The rate structure is simple.
On taxable profit up to this threshold, under the general taxation regime.
On taxable profit exceeding AED 375,000.
It is a real tax, with mandatory registration with the federal tax authority, annual returns, documentation obligations and transfer-pricing rules aligned with the OECD standards. The difference from the earlier period is not just the rate — it is the emergence of a tax administration that requires, verifies and penalises.
This is where the most frequent misunderstanding arises. The free-zone regime was not abolished, but it was made conditional. A free-zone company benefits from the 0% rate only if it has Qualifying Free Zone Person status and only for qualifying income. The conditions are cumulative.
The core income-generating activities are effectively carried out there, with corresponding assets, staff and operating expenditure. Outsourcing is possible within strict limits and with real supervision. It is the same logic of economic substance found in any serious jurisdiction.
According to the categories set by the implementing decisions. Not all of a company's income falls into this category.
Non-qualifying income must not exceed the threshold represented by 5% of total revenue or AED 5 million, whichever is lower. Exceeding the threshold entails loss of the status.
Compliance with the rules for related-party transactions, with the corresponding documentation.
The company must not have elected to be taxed under the general regime.
NOTE: The consequences of non-compliance are more severe than most expect. A company that fails to meet the conditions in a tax period does not simply lose the benefit on the surplus income: under the implementing decision on qualifying income, it loses Qualifying Free Zone Person status from the beginning of the period in which the failure occurred and for the following four tax periods — a five-year lockout. Throughout that period, all taxable income, including what would have qualified, is taxed under the general regime. Fixing the problem the following year does not reopen the door any sooner. In other words: free-zone status is not an administrative label obtained at incorporation, but a status that must be maintained and proven every year.
To this is added value-added tax, introduced in 2018, at a standard rate of 5%, and the related registration obligations.
Through Cabinet Decision no. 142/2024, the UAE introduced a Domestic Minimum Top-up Tax, applicable to financial years beginning on or after 1 January 2025. The mechanism ensures an effective tax rate of at least 15% for Emirati entities in multinational groups with consolidated revenue of at least EUR 750 million in at least two of the last four financial years. The UAE adopted only the domestic minimum tax, not the income-inclusion rule or the undertaxed-profits rule.
For the ordinary Romanian entrepreneur, this rule is irrelevant — the EUR 750 million threshold places it outside the discussion. It is, however, a signal about the underlying direction: the jurisdiction that presented itself as "zero tax" today applies, for large groups, exactly the global 15% standard.
These are two completely distinct things. The visa (the residence permit) is an immigration-law document. Tax residence is a status defined by tax legislation. In the UAE, the criteria for individuals are set by Cabinet Decision no. 85/2022, in force from 1 March 2023. An individual is a UAE tax resident if they meet one of the following conditions:
They have their usual or principal home and the centre of their financial and personal interests in the UAE.
They were physically present in the UAE for 183 days or more within a period of 12 consecutive months.
They were physically present for 90 days or more within a period of 12 consecutive months, are a UAE national, a national of a Gulf Cooperation Council state or a holder of a valid residence permit, and have a permanent home available in the UAE or carry on employment or a business there.
The tax residence certificate is issued by the federal tax authority, on request, if these conditions are met. Merely holding a visa is not sufficient for any of the three variants.
This is the only sentence that truly matters. A Romanian tax resident owes tax in Romania on income from any source, domestic and foreign. Under Art. 7(28) of the Tax Code, you are a Romanian resident if you meet at least one of the criteria: domicile in Romania, centre of vital interests in Romania, presence of more than 183 days in any interval of 12 consecutive months.
Consequently, if your family, home and economic ties remain here, you are a Romanian resident — however many Emirati visas you hold. The dividends received from the Dubai company are taxable in Romania and must be declared, at the rate applicable to dividend income, raised to 16% for dividends distributed from 1 January 2026 by Law no. 141/2025. And if both states consider you a resident, the conflict is settled through the successive criteria in Article 4 of the treaty: permanent home, centre of vital interests, habitual abode, nationality.
The second pitfall: the company managed from Romania. Even if your personal residence were correctly moved, the question about the company remains. Under Art. 7(37) of the Tax Code, a foreign legal entity whose place of effective management is in Romania is a Romanian tax resident, with profit taxed here. A free-zone company administered by e-mail from Romania is not an Emirati company from the perspective of Romanian law — it is an unregistered Romanian company.
Between Romania and the UAE there is a double-taxation agreement signed in Dubai on 4 May 2015, ratified by Law no. 26/2016, in force from 11 December 2016 and applicable from 1 January 2017; it replaced the 1993 agreement. The treaty caps the tax withheld in the source state on dividends, interest and royalties at 3%, where the recipient is the beneficial owner.
But here appears the mechanism no one explains on the terrace. According to the text of the agreement published by ANAF (the Romanian tax authority), Romania eliminates double taxation by the credit method: where a Romanian resident derives income that, under the agreement, is taxed in the UAE, Romania grants as a deduction from that resident's income tax an amount equal to the income tax paid in the UAE — but the deduction cannot exceed the part of the Romanian tax, computed before the deduction, attributable to that income. This is the ordinary credit, the same logic found in Art. 131 of the Tax Code for individuals.
The arithmetic consequence is brutal in its simplicity: the credit is zero if you paid nothing there. A double-taxation treaty eliminates double taxation; it does not create an exemption where there is only a single taxation. If the free-zone company is at 0% and you are a Romanian resident, you will pay in Romania in full, with nothing to credit.
The UAE signed the Multilateral Competent Authority Agreement and the Convention on Mutual Administrative Assistance in Tax Matters in April 2017, began identifying reportable accounts in 2017 and carried out the first automatic exchanges of information in September 2018. Today, the UAE exchanges data with more than 100 partner jurisdictions; domestic reporting is done by 30 June, and the international exchange by 30 September each year.
In practice: the balance of your personal Dubai account, the interest and the gross receipts reach ANAF through the same channel as the data from Switzerland or Luxembourg.
This means the centre of vital interests genuinely moved, physical presence documented, the departure questionnaire filed on time, the Emirati tax residence certificate and the company management genuinely exercised there. In practical order, a move that withstands scrutiny requires:
Taken first. If the spouse and children remain in Romania, the centre of vital interests remains, as a rule, here — and the rest of the steps do not compensate.
The one in the UAE becomes the principal one and documented (lease, utilities in your name); the one in Romania, if you keep it, is let long-term to a third party, so that it is no longer at your disposal.
Filed with the Romanian tax authority, within the legal deadline, with the evidence of the new life attached.
Obtained for each relevant year — not once, at the outset.
Stamps, tickets, contracts, statements — the proof is built as the year passes, not at the inspector's request.
Decisions taken in the UAE, real meetings, operating expenditure consistent with the declared activity.
Where businesses, accounts or mandates remain in Romania, they must have an explanation that does not contradict the departure declaration.
It is a life decision, not a tax one. Its costs — schools, housing, distance from extended family, rebuilding a professional network — are real and must be weighed honestly. What does not work is the hybrid variant: a life in Romania, a structure in Dubai, and the hope that no one compares the two. In practice, the comparison is precisely the simplest operation the administration performs: CRS data show the account, the Emirati commercial register shows the licence, and the Romanian records show the family, the home and the days spent here. For those who genuinely work from several countries, the discussion moves to the tax regime for digital nomads.
It is an important document, but it does not settle the discussion on its own. If Romania also considers you a resident — on the domicile or centre-of-vital-interests criterion — there is a dual-residence conflict, resolved through the successive tie-breaker criteria in Article 4 of the treaty. On the permanent-home and centre-of-vital-interests test, a family and a home in Brașov weigh more than a certificate.
Possibly. If the place of effective management is in Romania, the company is a Romanian tax resident and the profit is taxed in full here, regardless of distributions. Separately, if the conditions of Art. 40^5 of the Tax Code on controlled foreign companies are met, certain undistributed income may be taxed directly at your level.
No, if you have Qualifying Free Zone Person status. The exemption threshold belongs to the general regime. A qualifying free-zone company has 0% on qualifying income and 9% on the rest, without the AED 375,000 threshold. It is a distinction that completely changes the calculation for companies with mixed income.
A home available in Romania is the first criterion in the treaty tie-breaker and a heavy element in the centre-of-vital-interests analysis. It is not, in itself, fatal — especially if it is let long-term to a third party, so that it is no longer at your disposal. But if it remains free and furnished, "ready at any time", it will be invoked against you. Document the situation from day one.
This article is strictly informational and does not constitute legal or tax advice. Individual situations must be analysed case by case. Legislative position reflected: 18 July 2026.
Deadlines run from the moment of communication. An initial discussion clarifies what is being alleged, what you need to justify and how the defence is built — before an estimate becomes a tax assessment.