Singapore VCC insights

UAE Tax Residency Certificate for Individuals: Proving Residence in Dubai and Singapore When You Split the Year

By VCC Editorial Team · Published 10 November 2026

Short answer: A principal splitting the year proves UAE residence with a Federal Tax Authority certificate under Cabinet Decision No. 85 of 2022, and Singapore residence with an IRAS certificate of residence. If both countries claim him, Article 4(3) of the Singapore-UAE treaty decides: permanent home, centre of vital interests, habitual abode, then mutual agreement.

This article is general information only and is not legal, tax or investment advice. For matters needing legal advice, we work with a panel of experienced Singapore law firms.

A principal with homes in Dubai and Singapore may need proof of residence for a foreign withholding agent, a treaty claim or a private bank’s onboarding file. The UAE tax residency certificate for individuals and the IRAS certificate of residence rest on different tests, cover different periods and serve different readers. This note covers what each country requires and how the Singapore-UAE Avoidance of Double Taxation Agreement (DTA) settles a case where both claim the same person. It also covers what a Singapore bank’s Common Reporting Standard (CRS) self-certification asks for. Sources were checked on 10 November 2026 on tax.gov.ae, mof.gov.ae and iras.gov.sg. Immigration status and permanence are covered in our earlier note, UAE Golden Visa vs Singapore PR.

Who counts as a UAE tax resident individual?

An individual is UAE tax resident if he meets any one of the three tests in Article 4 of Cabinet Decision No. 85 of 2022. The tests are alternatives, so one is enough.

In the FTA’s unofficial translation, the tests are:

1. the person’s “usual or primary place of residence and the centre of his financial and personal interests are in the State”;
2. physical presence of 183 days or more “within the relevant (12) twelve consecutive months”; or
3. presence of 90 days or more in that period, by a person who is a UAE or GCC national or “holds a valid Residence Permit in the State”, and who either has a permanent place of residence in the UAE or carries on employment or business there.

Ministerial Decision No. 27 of 2023 (issued 22 February 2023) explains how the tests work in practice. Usual residence is where the person “spends most of his time when compared to any other jurisdiction as part of his settled routine”. The centre of interests looks at occupation, family and social ties, business and where property is administered. All “days or parts of a day” count, and the days need not be consecutive. A permanent place of residence is a dwelling “made continuously available” to the person, and it “can be rented”.

For a principal with a UAE residence visa and a flat in Dubai, the 90-day test is the one that matters, and part days count towards it.

How do you apply for a UAE tax residency certificate for individuals?

You apply online through the FTA’s EmaraTax platform. You state whether the certificate is for a double taxation agreement or for other purposes, and you pay the fees before you submit.

For a certificate issued for other purposes, the FTA service card (last updated 22 October 2026) sets out documents according to the test relied on:

• 183 days or more: an Emirates ID, or a passport with an entry and exit report from the Federal Authority for Identity and Citizenship or a local government entity.
• 90 to 182 days: an Emirates ID and passport with an official entry and exit report, plus proof of UAE employment or business or of a permanent place of residence.
• Centre of interests: the same identity documents, plus proof of financial and personal interests in the UAE, proof of primary residence and, if applicable, proof of source of income.

For a treaty certificate, the card asks for an Emirates ID and/or passport with an entry and exit report, proof of UAE income or salary if applicable, and any further evidence the treaty requires. For a treaty certificate “the passport is always mandatory”. Treaty certificates are issued under Ministerial Decision No. 247 of 2023 and name the treaty and the dates covered.

Fees are set by Cabinet Decision No. 65 of 2020 and are not refunded on rejection. There is a submission fee of AED 50 and a review fee of AED 1,000 for an individual without a Corporate Tax registration number (AED 500 for a registrant). Each hard copy costs AED 250. The FTA aims to decide within 10 business days. A certificate “cannot be issued to cover a future period” or a period of more than 12 months. An individual “can apply as soon as the criteria to be Tax Resident in the UAE are met”.

When is an individual tax resident in Singapore?

Singapore looks at the calendar year before the year of assessment. A foreigner is generally resident after 183 days in Singapore in that year. A citizen or permanent resident is resident if he normally lives in Singapore apart from temporary absences.

The IRAS guidance on tax residency sets out three routes for foreigners:

• 183 days or more of stay or work in Singapore in the previous calendar year;
• a three-year administrative concession for a continuous stay over three consecutive years, even if the first or third year is under 183 days; and
• a two-year concession for employees whose employment straddles two calendar years with at least 183 continuous days. Directors, public entertainers and professionals are excluded.

IRAS also describes treating a foreigner with a work pass valid for at least one year as resident, and reviewing that at tax clearance. Work passes and permanent residence are covered on our sister site, Singapore Employment Agency. A principal on the board of his own single family office is a director, so the two-year concession is not open to him. Singapore permanent residence does not by itself make anyone tax resident. Like the UAE rules, the Income Tax Act 1947 counts presence for part of a day as a full day.

What is the IRAS certificate of residence for individuals?

It is a letter certifying that the holder is Singapore tax resident, so that he can claim benefits under one of Singapore’s tax treaties. Individuals apply through myTax Portal or, where an overseas form needs endorsing, on paper.

IRAS’s application page for individuals sets out separate routes for citizens and permanent residents, the self-employed and foreign employees. An applicant who needs IRAS to endorse an original overseas tax form posts the paper application form together with it. IRAS states that applications are processed in two to three weeks. We found no certificate of residence (COR) fee in the IRAS sources read today, so none is quoted.

The Singapore certificate is narrower than the UAE one. IRAS issues it only for treaty claims, and its COR FAQs, written for companies, tie each certificate to a calendar year. The FTA also issues certificates “for purposes other than the application of a DTA”.

How does the Singapore-UAE treaty break a tie?

Where both countries treat an individual as resident under their own laws, Article 4(3) of the treaty applies its tests in turn: permanent home, then centre of vital interests, then habitual abode. If those do not settle the question, the two tax authorities decide by mutual agreement.

In the consolidated treaty text on the IRAS website, Article 4(1) defines a resident as a person resident “in accordance with the taxation laws of that State”. Article 4(3) provides:

1. He is resident where “he has a permanent home available to him”. If he has one in both countries, he is resident where “his personal and economic relations are closer (centre of vital interests)”.
2. If the centre of vital interests cannot be determined, or he has a permanent home in neither country, he is resident where he has “an habitual abode”.
3. If he has an habitual abode in both countries or neither, “the competent authorities of the Contracting States shall settle the question by mutual agreement”.

There is no nationality step. A principal with homes and family in both cities may therefore end up in the mutual agreement procedure under Article 25. Under Article 25, a case must be presented “within three years from the first notification” of the action that gave rise to the taxation. The Second Protocol, signed on 31 October 2014 and in force since 16 March 2016, changed only the list of government bodies in Article 4(2). The MLI changes, in force from 1 September 2019, added a principal purpose test in a new Article 27A and left Article 4 untouched.

Article 6 of Cabinet Decision No. 85 of 2022 applies a treaty’s residence rules “for the purposes of this International Agreement”, so the tie-breaker settles residence for treaty purposes only. For the wider treaty picture, see our note on the Singapore tax treaty network for family offices.

What happens in a split year?

The two systems measure different periods, so in the year of a move a principal can be resident in both for overlapping months.

Singapore gives one status per year of assessment, based on the preceding calendar year. The UAE tests run on any “relevant (12) twelve consecutive months”. A principal who moves to Dubai part-way through a year can pass the 90-day test within months. Singapore may still treat him as resident for that calendar year, for example because he spent 183 days there before leaving. A practical sequence:

1. Keep one day-count ledger from passport stamps and the UAE entry and exit report, counting part days in both countries.
2. Test the UAE rules against every rolling 12-month window.
3. Test the Singapore rules for each calendar year, remembering that directors cannot use the two-year concession.
4. Where both countries claim residence, work through the Article 4(3) tests: homes, closer ties, habitual abode.
5. Match the certificate period to the income or bank enquiry concerned, since the UAE will not certify a future period.
6. Update CRS self-certifications at each bank promptly after the change.

The tax effect is worked through in our Singapore vs Dubai tax calculation.

What will a private bank ask for in a CRS self-certification?

A Singapore bank must establish every jurisdiction in which an account holder is tax resident, through a self-certification it checks against its account-opening records. It cannot accept a claim of no residence without an explanation and evidence.

The IRAS e-Tax Guide “Common Reporting Standard” (Fourth Edition, 31 October 2025) requires banks to “maintain arrangements to establish the tax residencies” of account holders. Where a holder declares Singapore residence, the bank must obtain a Singapore tax reference number “to substantiate the claim”. The IRAS FAQs on the CRS (updated 23 October 2021) add three points:

• A self-certification that gives no tax residence (and no tax identification number) is not valid. Unless the holder provides “a reasonable explanation and appropriate documentary evidence”, the bank “should not proceed to open the account” (FAQ E.3).
• The bank must check that the self-certification is reasonable against its account-opening records. If it fails that check after opening, the bank must obtain a new form or an explanation within 90 days (FAQ E.6).
• After a change of circumstances, the bank cannot rely on the original form (FAQ E.15).

Either certificate is useful supporting evidence, but neither replaces a self-certification listing every jurisdiction of residence. A principal who meets the UAE 90-day test and is still Singapore resident should expect questions about both. The CRS changes due from 2027 are covered in our note on CRS 2.0 and CARF in Singapore.

How do the tests and documents compare?

Item	UAE	Singapore
Legal basis	Cabinet Decision No. 85 of 2022, Article 4; Ministerial Decision No. 27 of 2023	Income Tax Act 1947 (“resident in Singapore”); IRAS concessions
Day count	183 days in 12 consecutive months; 90 days with permit and home or work	183 days in the preceding calendar year
Qualitative test	Usual residence and centre of financial and personal interests	Citizens and permanent residents who normally reside here
Concessions	Exceptional-circumstance days may be disregarded	Three-year concession; two-year concession for employees, not directors
Part days	Count as days	Count as days
Certificate	FTA certificate, for treaty or other purposes	IRAS certificate of residence, for treaty claims
Core documents	Emirates ID and/or passport with entry and exit report; proof of home, work or interests	myTax Portal application; paper form if an overseas form needs endorsing
Period	Up to 12 months; no future periods	Calendar year (IRAS COR FAQs for companies)
Fees	AED 50 plus AED 1,000 (AED 500 if registered); AED 250 per hard copy	Not stated in the IRAS sources read
Processing	10 business days	Two to three weeks

Frequently asked questions

Can I get a UAE certificate after 90 days in Dubai?

Yes, if you also hold a valid UAE residence permit (or are a UAE or GCC national) and either have a home available in the UAE or work or do business there. Expect to provide an Emirates ID, a passport with an entry and exit report, and proof of the home or work.

Does a UAE certificate prove I am not Singapore resident?

No. It certifies UAE residence only. If Singapore also treats you as resident, Article 4(3) of the treaty decides residence for treaty purposes.

Does nationality break a tie under the treaty?

No. If permanent home, centre of vital interests and habitual abode do not settle it, Article 4(3)(c) leaves the case to the two tax authorities to resolve by mutual agreement.

Can I tell my bank I am resident nowhere?

Not without a reasonable explanation and documentary evidence, which IRAS expects the bank to obtain.

Sources

• Cabinet Decision No. 85 of 2022 on Determination of Tax Residency (FTA unofficial translation)
• Ministerial Decision No. 27 of 2023 (FTA unofficial translation)
• Federal Tax Authority, Issuance of a Tax Residency and Commercial Activity Certificate
• IRAS, Singapore-United Arab Emirates DTA (with Second Protocol and MLI modifications)
• IRAS FAQs on the Common Reporting Standard (updated 23 October 2021)

Raffles Corporate Services helps family office principals and fund managers with Singapore entities, VCC incorporation, family office set-up and ongoing compliance, including the records behind a Singapore residence position. Email hello@rafflescorporateservices.com or Call/SMS/WhatsApp +65 8501 7133, or visit Raffles Corporate Services.

Last reviewed: 10 November 2026. The Editorial Team, Variable Capital Companies Act.