Tax Residency in Dubai: A Case Study

A couple of taxpayers who believed they were tax residents of Dubai in 2016 and 2017 were subject to a tax audit.

Following this,administration that they should be considered French tax residents.

The tax reassessment was challenged all the way to the Administrative Court of Appeal, which first examined whether the taxpayers were, under French law, tax residents of France before applying the tax treaty.

Under French law, the Court notes that taxpayers have their domicile in France because:

• The receipts for a lease signed by a company were issued solely in the name of Mr.

• A contract had been signed with Enedis for an active meter, and the bills were issued in the names of family members

• The man was registered with the French social security system and had received reimbursements for medical expenses, deposited into a French bank account, during the years in question

• the taxpayers were married in France in 2016

• The man stated on social media that he lived in Paris

With regard to the tax treaty, the Court will note that the taxpayers have demonstrated that they are tax residents of both Dubai and France. 

The Court notes that the man has been a co-owner of an apartment in Dubai since January 2016 and has been a tenant since September 2017.

The Court will, however, find that the couple had closer personal and economic ties to France because:

• they had gotten married in France during the post-war years

• The company's headquarters—which was the source of its revenue and which the gentleman managed—was located in France

• No evidence of such a strong link in Dubai was reported

The judges therefore ruled that the taxpayers could not be considered residents of Dubai under the tax treaty, and subsequently upheld the tax assessment.

CAA Paris, Nov. 5, 2025, No. 24PA02106

This monitoring service is provided by Mispelon Avocat, a law firm specializing in tax audits and tax litigation. You can stay updated by subscribing to the newsletter via this link.