UAE individuals and companies can own an Australian proprietary company outright, as long as at least one director ordinarily lives in Australia. Before you plan cash flows, the key fact is that Australia has no comprehensive tax treaty with the UAE. Dividends, interest and royalties paid to a UAE owner are withheld at Australia's domestic rates. Neither the 2025 trade agreement nor the investment agreement changes that. The UAE is also outside the Apostille Convention, and its investors don't get the higher FIRB thresholds reserved for FTA partners.
Tax: planning without a treaty
We checked Treasury's income tax treaties list on 27 October 2026, and it doesn't include the United Arab Emirates. So the ATO's default withholding rates apply to UAE-resident recipients:
| Paid by the Australian company to a UAE owner | Australian withholding |
|---|---|
| Fully franked dividend | None |
| Unfranked dividend, or the unfranked part | 30% |
| Interest | 10% |
| Royalty | 30% |
Three consequences follow.
- Franking decides the dividend outcome. The ATO doesn't require withholding on fully franked dividends. An Australian company that has paid Australian tax and franks its dividends can pay a UAE parent with no further withholding. Unfranked profits face 30% on the way out.
- Royalties are expensive. A UAE group charging its Australian arm for a brand or technology licence faces 30% withholding on the royalty, with no treaty to reduce it.
- The structure gets examined. Groups sometimes hold Australian investments through a company in a country that does have an Australian treaty. Whether treaty benefits are then available depends on beneficial entitlement and anti-avoidance rules, including those added to many treaties by the Multilateral Instrument. This needs specialist tax advice in both countries, and we don't give it.
The Australian company itself pays Australian company tax at 25% or 30% on its profits whatever its owner's tax position at home. See our company tax guide.
What CEPA does and doesn't do
According to DFAT, the Australia–UAE Comprehensive Economic Partnership Agreement and the separate Agreement on the Promotion and Protection of Investments both entered into force on 1 October 2025. They deal with trade and investment protection. They are not income tax treaties, and they don't appear on Treasury's tax treaty list.
The investment agreement also hasn't placed the UAE among FIRB's "certain FTA partners". The 2026 threshold table lists those partners by name, and the UAE isn't one of them.
FIRB thresholds for UAE investors
Under the 2026 monetary thresholds, in force since 1 January 2026, a private UAE investor is in the "not from certain FTA partners" group:
- Acquiring 20% or more of an Australian entity: more than $347 million, whether or not the business is sensitive.
- Developed commercial land: more than $347 million, or more than $75 million if the land is sensitive.
- Agricultural land: more than $15 million (cumulative).
- Agribusiness, by direct interest (generally 10% or more): more than $75 million (cumulative).
- Residential land, vacant commercial land and national security land or businesses: $0, the same as for every investor.
Thresholds follow the immediate acquirer. A UAE family that buys through, say, a Singapore holding company is assessed on Singapore's thresholds, not the UAE's.
Government-linked capital
If any of the money comes from a state-owned fund or company, check this first. For FIRB, foreign government investors face a $0 threshold on all investments, so even a small stake can need approval. Ask an adviser whether the definition reaches your investor, including a company with government-linked shareholders, before term sheets are signed. Our FIRB basics guide covers which actions are notifiable. We don't give FIRB advice.
Documents without an apostille
The HCCH status table for the Apostille Convention lists several Gulf states, but not the United Arab Emirates. That removes the shortcut available to Korean or European owners.
For Australian tax registrations, the ATO's certification rules accept copies certified outside Australia by:
- a notary public, or
- staff at an Australian embassy, high commission or consulate.
The certifier must sight the original and copy together, then sign, date and annotate each page with their name, phone number and qualification. Documents in Arabic need an English translation by an approved translation service.
Banks, and anyone else outside the ATO, may set their own requirements and sometimes ask for a full legalisation chain. Ask each receiving party what it accepts before booking a notary. If the parent is registered in a free zone, send a sample of its certificate to whoever will verify it, so they know what to expect.
For our own onboarding, we need certified ID and proof of address for each director and beneficial owner, plus the group structure chart. Ask us before paying for certification if you're unsure a certifier will be accepted.
Running a board across six or seven hours
Dubai and Abu Dhabi are on Gulf Standard Time, UTC+4, with no daylight saving.
- April to early October (Sydney on AEST, UTC+10): Sydney is 6 hours ahead of the UAE.
- Early October to early April (Sydney on AEDT, UTC+11): Sydney is 7 hours ahead.
- Perth (UTC+8, all year): 4 hours ahead of the UAE.
Only a narrow live window works: Sydney mid-afternoon is UAE morning. A 3pm Sydney call in July is 9am in Dubai. In January the same 9am Dubai start is 4pm in Sydney. Sydney-based directors will usually prefer documents to arrive by UAE afternoon, so they can be read overnight Sydney time and signed the next morning. For time-critical deals, plan for a one-day turnaround on every signature, and a Perth-based director narrows the gap by two or three hours.
Confirm the working days of everyone involved, including any Friday early close, when you build a closing timetable.
Typical structures
UAE individual founder, Australian Pty Ltd. The most direct route. The founder holds the shares, the resident director meets s201A, and the founder can still be a director from Dubai with a Director ID. See registering a company as a foreigner.
Free zone holding company as parent. A bank opening the Australian account will want to see who ultimately owns and controls the parent. The ABN application asks for the Australian company's associates, not the parent's.
Holding through a third country. Changes the FIRB thresholds and possibly the tax position. Decide it with advisers, not by default.
How we work with UAE owners
We provide the Australian-resident director and run the ASIC calendar, including the $342 annual review fee and the solvency resolution. Our acceptance checks look closely at ownership, and structures that obscure who owns the company are declined. Appointment is typically within 5 business days of completed checks. Use the cost calculator for a first-year estimate, then start here when you're ready.
This page is general information current at 27 October 2026. It is not legal, tax or FIRB advice. Take advice in Australia and the UAE before you invest.
Frequently asked questions
Is there a double tax treaty between Australia and the UAE?
No. The UAE does not appear on Treasury's list of Australia's income tax treaties as at October 2026, so there is no comprehensive tax treaty. Australian domestic withholding rates apply to payments from an Australian company to a UAE owner.
Doesn't the Australia–UAE CEPA cover tax?
Not in the sense of a tax treaty. CEPA is a trade agreement, which came into force with a separate investment agreement on 1 October 2025. Neither reduces Australian withholding tax the way a tax treaty would.
Can UAE documents be apostilled for Australia?
The UAE is not listed as a party to the Apostille Convention. Certified copies for Australian tax registrations can be made by a notary public or by staff at an Australian embassy or consulate instead.
Is a UAE sovereign fund treated differently by FIRB?
It can be. Foreign government investors face a $0 threshold for every investment in the 2026 table. Whether a particular fund, or a company it partly owns, counts as one is something to settle with a FIRB adviser before signing.
Official sources
- Treasury: Income tax treaties treasury.gov.au
- ATO: Withholding rate (payments to foreign residents) ato.gov.au
- ATO: Withholding from dividends paid to foreign residents ato.gov.au
- DFAT: Australia–UAE Comprehensive Economic Partnership Agreement dfat.gov.au
- Foreign Investment Australia: Monetary thresholds (2026 table) foreigninvestment.gov.au
- HCCH: Apostille Convention status table hcch.net
- ATO: Copies of identity documents for applicants outside Australia ato.gov.au
General information about Australian law and practice, not legal or tax advice for your circumstances. Check the official sources, or ask your adviser, before you act.