Moving to Dubai from France: What France Continues to Tax

Dubai attracts many departure plans driven by the absence of local personal income tax. The reasoning often stops there, wrongly. Two points are decisive: proof that the domicile has genuinely been transferred, and the continued French taxation of what remains in France.

The method for a departure is set out on our page on transferring your tax residence.

Does the UAE tax individuals’ income?

The United Arab Emirates does not, to date, levy any federal personal income tax. A corporate tax was, however, introduced by Federal Decree-Law No. 47 of 2022. According to the UAE Ministry of Finance, it may also apply to individuals carrying on a business activity there, under the conditions set by Cabinet decision. The regime applicable to an activity carried on there, in particular in a free zone, depends on its nature and location. These matters fall under local law and should be checked with an adviser on the ground before any decision.

The absence of local tax says nothing about the French position. It only makes the residence question more sensitive: where the host State levies no income tax, the whole issue in an audit is whether the departure is genuine.

How to prove your tax residence in the UAE

French tax domicile results from the criteria in Article 4 B of the French Tax Code (code général des impôts, CGI): home or principal place of stay, a professional activity that is not ancillary, centre of economic interests. A single criterion is enough to keep the link with France.

The evidence file is built at the time of departure.

• UAE residence visa and tax residence certificate issued by the competent authority.
• Lease or title deed for the home, electricity, water and telecommunications bills.
• Employment contract or registration of the business locally, including in a free zone.
• Children’s schooling and local health insurance.
• Bank statements showing where day-to-day spending actually takes place.
• Documentation showing that the home kept in France has actually been given up or let.

The factors examined by the tax authorities in an audit are detailed in our article on the audit of tax domicile.

What does the France–UAE tax treaty say?

The treaty between France and the United Arab Emirates was signed on 19 July 1989. Its approval was authorised by Law No. 90-333 of 10 April 1990 and it was published by Decree No. 90-631 of 13 July 1990. It entered into force on 1 July 1990 and was supplemented by a protocol of 6 December 1993.

Its distinctive feature is its scope: it covers taxes on income, on inheritances and on capital, which is rare (it does not cover gifts). This breadth means that the interaction with the French real estate wealth tax and with inheritance tax is not settled by French domestic law alone: it requires an examination of the treaty provisions applicable to each category of assets. For the UAE, its Article 4 defines as resident “any person who is domiciled, established, or has its seat of management” in the country (unofficial translation; French text: “toute personne qui est domiciliée, établie, ou a son siège de direction”); in the event of dual residence, the permanent home, then the centre of vital interests, habitual abode and nationality decide between the two States.

What France continues to tax

• French-source income listed in Article 164 B of the CGI, in particular income from property located in France, at the minimum rate of 20% and then 30% under Article 197 A.
• French real estate capital gains, at the 19% rate under Article 244 bis A, plus social levies. As the UAE is neither a member of the European Union nor a party to the European Economic Area, an accredited tax representative must in principle be appointed (IV of Article 244 bis A of the CGI).
• The French real estate wealth tax (IFI) on French real estate, subject to the treaty provisions applicable to capital.
• Gifts and inheritances falling within Article 750 ter of the CGI, subject to the treaty provisions on inheritance.

The exit tax under Article 167 bis may apply on departure. Automatic deferral requires the host State to meet the conditions of administrative assistance and recovery laid down by that article: this point is checked at the date of the transfer. Failing that, the deferral application must be filed no later than ninety days before departure, with security provided.

A worked example

A company director moves to Dubai in January 2026 and carries on a consulting business there. His spouse and two children join him. He keeps a flat in France let for €30,000 a year and valued at €950,000, and holds 55% of the share capital of a French company, a shareholding valued at €2,800,000 with a cost price of €150,000.

• French rental income: taxable in France. The 20% minimum rate applies to €30,000, with the 30% rate applied to the portion above €29,579. The minimum tax comes to approximately €6,042, excluding social levies.
• IFI: the French real estate assets, €950,000, remain below the €1,300,000 threshold. No IFI is due.
• Exit tax: as the shareholding carries rights to more than 50% of the company’s profits, Article 167 bis applies. The unrealised gain amounts to €2,650,000, giving an assessed tax of €339,200 at the 12.8% rate, excluding social levies. As deferral is not necessarily automatic, the application must be prepared ninety days in advance.
• If the spouse and children had stayed in Paris: the home criterion would have kept the French tax domicile, and all worldwide income would have remained taxable in France.

Who this move suits, and who it does not

It may suit a person who genuinely moves their home there, carries on their activity there and is prepared to document their presence over time.

It is a poor fit for someone whose family stays in France, for someone who retains effective management of a French business, and for someone whose wealth is mainly French real estate.

Key points

• The absence of local income tax shifts the whole issue to proof that the domicile has genuinely been transferred.
• The treaty of 19 July 1989 covers income, capital and inheritances: it must be examined before reaching any conclusion on IFI or gift and inheritance duties.
• Exit tax deferral is not necessarily automatic: the application is prepared ninety days before departure.

FAQ

Is there income tax in the UAE?
The United Arab Emirates does not, to date, levy any federal personal income tax. A corporate tax has been introduced, which may also apply to individuals carrying on a business activity there: the regime applicable to that activity should be checked with a local adviser.

How do I prove that I genuinely live in Dubai?
Through a body of material evidence: residence visa, tax residence certificate, lease and bills, business declared locally, children’s schooling, location of day-to-day spending.

Does my French income remain taxable?
Yes, for the French-source income listed in Article 164 B of the CGI, at the minimum rate of 20% and then 30% under Article 197 A, subject to the treaty provisions.

Will I pay IFI from Dubai?
IFI applies to French real estate above €1,300,000 of net taxable value. As the France–UAE treaty covers capital, its interaction with Article 964 of the CGI must be examined on the basis of the documents.

Does exit tax apply?
It applies if the thresholds of Article 167 bis are reached. Whether the deferral is automatic depends on the assistance agreements in force at the date of the transfer: failing that, the application is filed ninety days before departure, with security.

Assessing your move to the UAE

We build the evidence file, handle the exit tax return and analyse the treaty for each category of assets. See our notes on Switzerland and on Belgian taxation, our article on the personal tax audit and our page on leaving France in compliance with the rules. Every situation is different and deserves a dedicated analysis.

Official sources

• Tax treaty between France and the United Arab Emirates of 19 July 1989, full text – impots.gouv.fr (in French)
• BOFiP, tax treaty between France and the United Arab Emirates – bofip.impots.gouv.fr (in French)
• BOFiP, list of tax treaties concluded by France – bofip.impots.gouv.fr (in French)
• Article 4 B of the French Tax Code (code général des impôts), tax domicile – Légifrance (in French)
• Article 164 B of the French Tax Code (code général des impôts), French-source income – Légifrance (in French)
• Article 244 bis A of the French Tax Code (code général des impôts), real estate capital gains of non-residents – Légifrance (in French)
• Article 964 of the French Tax Code (code général des impôts), real estate wealth tax – Légifrance (in French)
• Article 167 bis of the French Tax Code (code général des impôts), exit tax – Légifrance (in French)

This article sets out the law for general information purposes, as verified at the date of publication. Foreign law is presented subject to confirmation by a local adviser. It does not constitute legal advice. Every situation is different and deserves a dedicated analysis. Content compliant with the professional conduct rules of the legal profession.