I'm based in Dubai and own a Wyoming LLC — does UAE's 9% corporate tax apply to my U.S. LLC profits?

Federal Decree-Law No. 47 of 2022 ('the Corporate Tax Law') introduced UAE federal corporate tax effective for financial years starting on or after 1 June 2023. The headline rates:

• 0% on taxable income up to AED 375,000 (approximately USD 102,000)

• 9% on taxable income above AED 375,000

• 15% on income subject to the Pillar Two Global Minimum Tax (effective from 2025 for entities in scope — multinational groups with consolidated revenue over EUR 750M)

The law applies to all 'taxable persons,' which includes:

• UAE resident juridical persons (companies incorporated in the UAE, including mainland and free-zone entities)

• Foreign juridical persons that are 'effectively managed and controlled' in the UAE (POEM rule)

• Natural persons (individuals) who conduct a 'business or business activity' in the UAE — but only on income from that business, and only if annual turnover from such business exceeds AED 1,000,000 (approximately USD 272,000) under Cabinet Decision No. 49 of 2023.

A non-resident person is taxed only on UAE-source income — i.e., income attributable to a UAE permanent establishment, UAE real estate, or specified types of UAE-source income.

Key for you: the question is whether your Wyoming LLC is a UAE resident through the POEM test, or whether the LLC's profits are attributed to you as a UAE-resident individual conducting business in Dubai.

Under Article 11(3)(b) of the Corporate Tax Law, a foreign juridical person is a UAE Resident Person if it is 'effectively managed and controlled in the UAE.' This is the Place of Effective Management (POEM) concept used in many tax systems.

The Federal Tax Authority's Ministerial Decision No. 27 of 2023 and supplementary guidance clarify that POEM is determined by where:

• Key management and commercial decisions are in substance made

• Board of directors or equivalent senior management normally meets

• Strategic decisions are taken

For a foreign-owned single-member U.S. LLC managed by a single individual sitting in Dubai, every key decision is being made in the UAE. Even though the LLC is registered in Wyoming and has a Wyoming registered agent, the substantive decision-making — what services to offer, what clients to take, what contracts to sign, when to invest, when to distribute — is happening in the UAE.

Applied to your facts: it is highly likely that your Wyoming LLC is treated by the FTA as a UAE Resident Person under POEM. As a UAE Resident Person, the LLC's worldwide income is subject to UAE corporate tax (subject to participation exemptions, foreign tax credit, and the 0% / 9% bracket structure).

The alternative analysis: even if FTA were to accept that POEM is in Wyoming (perhaps because contracts are signed remotely with U.S. counterparties and the LLC has U.S. service providers), you as the individual UAE resident may still be taxed on the LLC's income if the FTA treats the LLC as transparent and the income as your individual business income. UAE individuals are taxed on business income over AED 1M annual turnover.

Several reliefs in the UAE corporate tax law might reduce your exposure:

1. Small Business Relief (Ministerial Decision No. 73 of 2023): A resident person with revenue not exceeding AED 3,000,000 (approximately USD 817,000) in a tax period can elect to be treated as having no taxable income for that period. The relief is available for tax periods ending on or before 31 December 2026. If you elect, you file a simplified return and pay no corporate tax. This is the most likely useful relief for a solo consultant.

2. 0% bracket on first AED 375,000: Even without Small Business Relief, the first AED 375,000 of taxable income is taxed at 0%. For a single-person consulting business with profit under AED 375K (about USD 102K), no tax is owed.

3. Free-zone person regime (if you have a UAE free-zone entity): A 'Qualifying Free Zone Person' may pay 0% on qualifying income and 9% only on non-qualifying income. This regime is designed for UAE free-zone companies, not for foreign LLCs — but if you also have a UAE free-zone entity, restructuring through that entity may capture better treatment.

4. Participation exemption (Article 23): Dividends and capital gains from a 'Participating Interest' (5%+ stake held over 12 months, in a foreign company taxed at 9%+ in its home jurisdiction, OR a company with non-passive income test) may be exempt from UAE corporate tax. For a U.S. C-corporation (21% federal rate), this likely qualifies. For a disregarded LLC, the foreign-tax-rate test is harder to meet because the LLC pays no entity-level U.S. tax.

Key records to maintain: monthly bookkeeping in USD (for U.S. Form 5472) and in AED (for UAE CT), bank statements for both jurisdictions, client invoices with delivery location notes, signed contracts with date and location of signing, board minutes or owner resolutions for major decisions, and proof of UAE physical presence (residency visa, Emirates ID, lease, utility bills).

1. Register for UAE corporate tax via the EmaraTax portal within 9 months of the financial year in which you became a taxable person, if you haven't already. The deadline applies whether you ultimately owe tax or just elect Small Business Relief.

2. Decide your tax period. Most individuals align with the calendar year (January–December). The LLC's U.S. tax year and your UAE tax period don't have to match exactly — but using the same dates simplifies reconciliation.

3. Calculate UAE taxable income under International Financial Reporting Standards (IFRS) for SMEs. This is the UAE CT starting point. Adjust for non-deductible items per Article 28–33 of the Corporate Tax Law. The result is your taxable income.

4. Apply Small Business Relief if revenue is under AED 3M and you want zero tax. Otherwise, compute tax: 0% on first AED 375K, 9% on excess.

5. File the UAE corporate tax return within 9 months of the tax period end. The FTA's EmaraTax system handles the filing.

6. On the U.S. side, continue filing Form 5472 + pro forma 1120 for the LLC. UAE corporate tax payments to the FTA may be creditable on the LLC owner's home-country return — but since you are UAE resident and the UAE is now the home country, the credit question for U.S. tax doesn't typically arise for a non-U.S. owner.

For amounts over AED 375K and especially over AED 3M, engage a UAE-licensed tax adviser familiar with Federal Decree-Law 47 and its supplementary decisions. The law and its implementing Ministerial Decisions are continuing to evolve, and audit defense expectations are still being established.