Getting a UAE Tax Residency Certificate (TRC) from the FTA is one
thing. Getting foreign tax authorities
to accept it is another. Many businesses mistakenly assume that a license and a
PO box are enough — but tax authorities like India’s will dig deeper. If your
TRC was denied or ignored, here’s how to rebuild your structure and reapply
successfully.
- ❌ No audited financials or bank account in the UAE
- ❌ 100% income from one country (e.g., India) — seen as a conduit
- ❌ Board meetings not held or documented in the UAE
- ❌ No UAE-based staff or directors
- ❌ Application showed “form over substance” — meaning paper
setup, no operations
Practical
Examples
Indian Client Exposure –
Rejected TRC
A UAE Free Zone company under IFZA billed over AED 700,000 annually
to one Indian client. It held a valid license, but:
- No UAE
office or staff
- No board
meeting minutes
- No UAE
bank trail
- All
operations handled from India by the founder
India applied GAAR (General Anti-Avoidance Rule) and ignored the UAE
TRC. With 10% withholding and reputational damage, the client turned to
Fastlane.
The Fix
We helped the company:
- Set up a
serviced office and attend board calls from UAE
- Hire a
part-time admin and show UAE-based costs
- Route
revenue through a UAE bank
- Revise
contracts to reflect UAE value creation
- Prepare
full audit and control log to reapply
Within 3 months, the TRC was approved, and the Indian client
accepted 0% WHT under the UAE-India DTA.
If your TRC was rejected or challenged, here's how to rebuild your
file:
- Substance Over Form
Add minimum UAE substance: a real office, staff (or contractors), decision
logs, and bank trail.
- PoEM Fix
Conduct board meetings from the UAE — physically or virtually — and
document location, time, and decisions.
- Diversify Revenue
Add at least one non-India client to avoid being labeled a conduit.
- Re-document
Collect UAE-based contracts, invoices, utility bills, and proof of UAE-led
control.
- Legal Justification
Support your application with references to UAE’s TRC Guide and OECD PoEM
guidelines.
If your TRC was denied, it doesn’t mean your UAE entity can’t qualify. But you must turn it from a “setup on paper” into a substantive, controlled, and active business based in the UAE.
At Fastlane, we’ve helped dozens of companies across SHAMS, RAKEZ,
IFZA, and Dubai South rebuild failed TRC structures
and reapply with confidence. Here’s how:
- ✅ Audit of your current TRC rejection
- ✅ Restructuring governance to meet PoEM standards
- ✅ Assistance with UAE-based hiring, leasing, and banking
- ✅ Board documentation and decision log creation
- ✅ Full TRC reapplication support and DTA letters for Indian and
UK tax relief
- ✅ If needed, we coordinate with legal advisors for opinion
letters
We’ve seen 3–6 month turnarounds from TRC rejection to approval —
with real economic substance that satisfies both FTA and foreign tax
authorities.
