The UAE Has Been Removed from the Ministry of Finance “Black List”: What Does This Mean in Practice?
Recently, it was announced that the UAE has been removed from the so-called “black list” of the Russian Ministry of Finance. This raised questions as to whether this change implies the launch of automatic exchange of information.
The short answer is no. Automatic exchange of information between the UAE and Russia has been in place since 2018, and nothing has changed in this regard.
The development relates to something else.
As of 1 January 2026, the UAE has been removed from the List of States and Territories Providing Preferential Tax Regimes (the Ministry of Finance’s “black list”).
What does this mean for businesses?
Removal from the list, together with the conclusion of a new double tax treaty, opens up a number of tax advantages for Russian groups holding assets in the UAE. In particular:
- tax relief may now be applied to the sale of shares and equity interests in UAE companies;
- a 0% withholding tax rate applies to dividends received from the UAE.
NB: These changes do not affect transfer pricing rules. Article 105.14 of the Russian Tax Code provides that transactions with counterparties from jurisdictions where the corporate income tax rate is 15% or lowerare treated as transactions with related parties. Since the corporate tax rate in the UAE is 9%, transactions with UAE counterparties — even independent ones — continue to qualify as controlled transactions once the turnover threshold of RUB 120 million is exceeded.
