Dubai investor visa to circumvent CRS will no longer work



Dubai FTZ Residence Visa sham


The UAE AEOI Guidelines Notes defines a UAE tax resident as "Resident Person" in the UAE means:
A. An Individual who is a resident in UAE with:
  1. a valid Emirates ID, and
  2. a valid Residency Visa
Financial Institutions will have to determine all the jurisdictions which have a tax claim on the individual based on Permanent home, Centre of Vital Interest, Habitual Abode.

Financial Institutions will not have to determine which jurisdiction has the sole tax claim on the account holder.

Account holders can provide evidence that they are not tax resident in a country the financial institution considers them resident.

Financial Institutions will no longer be allowed to accept residence visas and utility bill as proof of tax residence. Tax residence will be determined by the updated 2017 OECD Model Tax Convention.
The OECD Model Tax Convention page 87 gives a descending priority criteria of determining tax residence, when two states lay claim. This is (1) Permanent Home, (2) Centre of Vital Interest, (3) Habitual Abode, (4) Nationality and (5) Mutual Agreement by the states.