الموطن الضريبي في ظل التشريع الإماراتي

First: Books and periodicals:

I. Shawabkeh, Salem. Double taxation in taxes on income and methods of avoiding it with a comparative applied study. Damascus University Journal for Economic and Legal Sciences, Vol. 21, No. II, 2005, p. 62.

II. Al-Sattouf, Muhammad Al-Hussein, Rakaj, Muhammad Al-Khalaf Yahya. An analytical study of the payroll and wages tax in Syria, Journal of Economic and Legal Sciences. Tishreen University. Syria,. Vol. 25, No. 2 (2003), pp. 65-80.

III. Bin Talha, Al-Walid. Tax justice. Policy brief. Arab Monetary Fund. Issue (3) May، 2019.

IV. My wing, Wafa Yaqoub. The legal status of intelligent robots and the responsibility of their operator. An analytical study in Bahraini and comparative law. Journal of Law, Kuwait University. Number 3, Year 48, September 2024, 413- 457.

V. Hasina Sharon, The Position of the International Judiciary on the Conflict between Conventions and Internal Law, Al-Muthinker Magazine, Faculty of Law and Political Science, Mohamed Khider Biskra University, Third Issue, 2008, pp. 77-202.

VI. Hussein, Noor Hamza. International double taxation and ways to remedy it. Journal of Legal Sciences. College of Law. University of Baghdad. First issue, 2020, pp. 266-287.

VII. Abdel Redha, Abdel Rasoul and Abbas, Saad Khudair, The Principle of Terriality and Conflict of Laws, Dar Al-Sanhouri, Beirut, Lebanon, 2020.

VIII. Allam, Wael. The Status of the International Treaty in the Constitution of the United Arab Emirates, Journal of Sharia and Law, United Arab Emirates University, Vol. 28, No. 59, 2014, pp. 131-190.

IX. Friend, Ramadan. Egypt's gains from the conclusion of double taxation agreements. Egyptian Tax Association. Vol. 7, No. 27, 1997, pp. 148-113.

X. Mabrouk, Nazih Abdel Maksoud. The phenomenon of double taxation and the position of Islamic law on it, Journal of the Faculty of Sharia and Law in Tanta, Issue Thirty-seven, 2022, Part 2/2, p. 933.

XI. Dr. Moghaddam Aberat, Amna Al-Tunisi, Sarah Abdelali, The American, Swiss and Algerian Tax System, A Comparative Study, Journal of Tax Studies, Algeria, No. 2 June, 2013, pp. 79-111.

Second: Scientific Theses:

I. Jaafar, Ramlet Hussein. Double taxation (an applied study on the United Arab Emirates). Master's Degree in Public Law, University of Sharjah, 2014, p. 24.

II. Abdel Qader, Mustafa Mahmoud. Determine the tax profit of banks. PhD Thesis, Cairo University, 2004, p. 40.

III. Tariq Juma Saeed, Mechanisms of Localization of International Treaties in National Law, "A Comparative Study between Jordanian and Iraqi Legislation", Master's Thesis, Middle East University, Amman, Jordan, 2020.

Third: Laws and Regulations:

I. The Saudi Income Tax Law issued by Royal Decree No. (M/1) dated 15/1/1425 AH and its amendments.

II. Tax Procedures Law No. (28) of 2022.

III. The UAE Corporate and Business Tax Law promulgated by Federal Decree-Law No. (47) of 2022.

IV. Cabinet Resolution No. (74) of 2023 regarding the executive regulations of Federal Decree-Law No. (28) of 2022 on tax procedures.

V. Ministerial Resolution No. 27 of 2023 regarding the implementation of the provisions of Cabinet Resolution No. (85) of 2022.

VI. Cabinet Resolution No. (49) of 2023 regarding determining the categories of businesses or business activities practiced by a resident or non-resident natural person that are subject to corporate tax.

VII. Ministerial Resolution No. (247) of 2023 regarding the issuance of a tax residency certificate for the purposes of international agreements.

VIII. Cabinet Resolution No. (56) of 2023 regarding determining the relationship of a non-resident person in the State for the purposes of Federal Decree-Law No. (47) of 2022 regarding corporate and business tax.

IX. Ministerial Resolution No. (83) of 2023 regarding determining the conditions for not considering the presence of a natural person in the State as a reason for creating a permanent establishment for a non-resident.

X. Ministerial Resolution No. (43) of 2023 regarding the exception from registration for the purposes of Federal Decree-Law No. (47) of 2022 regarding corporate and business tax.

XI. Cabinet Resolution No. (85) of 2022 regarding determining the tax domicile.

XII. Arab Republic of Egypt. Decision of the Council of Ministers No. 991 of 2005 promulgating the Executive Regulations of the Income Tax Law promulgated by Law No. 91 of 2005, Official Gazette, No. 295 (continued), 27 December 2005.

XIII. Corporate Tax Guide, Tax on Income Arising from Foreign Sources Corporate Tax Guide, issued by the Federal Tax Authority, November 2023.

XIV. Explanatory guide regarding Federal Decree-Law No. 47 of 2022 regarding corporate and business tax.

XV. Corporate Tax Guide (Non-Resident Persons) issued by the Federal Tax Authority in October 2023.

Fourth: Foreign References:

I. OECD, Model Agreement on Exchange of information on Tax matters of 2002 (with detailed commentary), 2002, www.OECD.

II. Tax Residency in Egypt: Clarifying Residency Rules for Taxation, eg.andersen.com

III. Joseph Lipari, New York s changes to tax policy have Downsides for Nonresidents, new York Law Journal, April28, 2009.

IV. Tax information and responsibilities for new immigrants to the United States, An official website of the United States Government, Residency under U.S. tax law, internal Revenue service. https://www.irs.gov/7/2/2025:4:25AM.

V. The 4 Income Tax Systems Around the World, finance,6 December, 2023 . .https://nomadcapitalist.com/finance/4-tax- systems/7/2/2025.

VI. Foreign Account Tax Compliance Act (FATCA) – IRS. https://www.irs.gov/businesses/corporations/foreign-account-tax-compliance-act-fatca

Fifth: Websites:

I. https://www.hsbc.ae/content/dam/hsbc/ae/docs/ar/legal/uae-crs-faqs-tax-residency.pdf, 26/5/2024,13.14 PM.

II. www.Tax.gov.ae .

https://tax.gov.ae/ar/taxes/corporate.tax/faqs.aspx. https://taxsummaries.pwc.com/canada/individual/tax-administration .

III. Tax Residency in Egypt: Clarifying Residency Rules for Taxation, eg.andersen.com .

IV. Canda- Individual - Tax administration, 10 December 2024 .

V. Tax information and responsibilities for new immigrants to the United States, An official website of the United States Government, Residency under U.S. tax law, internal Revenue service. https://www.irs.gov/7/2/2025:4:25AM.

VI. Foreign Account Tax Compliance Act (FATCA) – IRS. https://www.irs.gov/businesses/corporations/foreign-account-tax-compliance-act-fatca.