CBAM and the United Arab Emirates

In 2025 the European Union imported goods worth €9.3 billion from the United Arab Emirates. Non-ferrous metals, the product group that includes aluminium, were €1.4 billion of this (14.8%). Iron and steel added €0.3 billion, or 3.4% (European Commission, 2026). Aluminium, iron and steel fall under the Carbon Border Adjustment Mechanism (CBAM).

The mechanism has applied since 1 January 2026. With verified emissions figures in the CBAM declaration, you can show the efficiency of your installation. You use this best in the European market when you control the import yourself.

The rules in the definitive phase

Six sectors fall within scope today: cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. Under Article 25 of the CBAM Regulation, customs authorities only allow an authorised CBAM declarant to import CBAM goods. The declarant buys its certificates from the competent authority in the EU Member State where it is established. An importer needs this status when it imports more than 50 tonnes of CBAM goods a year. For electricity and hydrogen, the status is needed from the first unit.

An exporter from outside the EU has two options. Its own EU company, such as a Dutch BV, applies for the status itself. Or an indirect customs representative with authorised CBAM declarant status files the declarations, and is then always the declarant. Both options, the legalisation of papers from the UAE and the work of our partners are in our guide for Gulf exporters that need an EU importer.

The first annual declaration covers calendar year 2026 and falls due by 30 September 2027. Certificate sales begin on 1 February 2027 through the common central platform. Since 1 January 2026, EU import declarations have a CBAM code in the additional reference field. All 2027 dates, including the first quarterly certificate check on 31 March 2027, are in our guide to the authorised CBAM declarant for non-EU exporters.

Benefits of a Dutch entity for Emirati exporters

If you sell through European buyers, you depend on them. They must already have authorised declarant status, and they pass the carbon costs back to you in their price. If you import through your own Dutch BV, you set the terms. Your BV buys certificates directly at the EU carbon price and uses your verified low-carbon figures as a sales argument. It invoices European customers as a European supplier under EU VAT rules.

To back that sales argument with numbers, compare the default value with your verified figure for aluminium or steel in the CBAM cost calculator for the UAE.

For large volumes of aluminium, the Article 23 licence is very useful. With this licence, your BV declares the import VAT later, in its periodic VAT return. Your company then keeps more cash for every shipment you import through Rotterdam.

Structuring the ownership chain

The Netherlands charges a conditional withholding tax of 25.8% on interest, royalties and dividends paid to related companies in countries on its list of low-tax jurisdictions (Belastingdienst, 2026). The tax can also apply to artificial structures. For 2026, the Dutch list of low-tax jurisdictions names Bahrain and leaves out the UAE. For owners in Bahrain and the UAE, our team checks the current list first.

The Netherlands and the UAE also have a tax treaty for income and corporate taxes. Under the treaty, the Dutch withholding tax on dividends to a UAE company is 5% from a 10% holding and 10% in other cases, and 0% on interest and royalties (treaty Articles 10 to 12). Decide on the ownership and the payments before the Dutch company is set up.

Before the notary drafts the deed, you plan this chain with us. Your structure is then correct at incorporation, and you avoid a reorganisation later.

Setting up in the Netherlands

A Dutch BV is incorporated by notarial deed and registered with the Chamber of Commerce (KvK). Incorporation is done from abroad by power of attorney, with the parent company owning the shares. After registration the BV obtains its VAT number and EORI number and applies for the Article 23 licence and the CBAM authorisation. The same entity then serves as the base for EPR registrations under the Packaging Regulation and for its European contracts.

Further reading: an EU entity for CBAM and fiscal representation and Article 23.

Frequently asked questions

Can a UAE company import CBAM goods into the EU directly?

Only an authorised CBAM declarant may import CBAM goods. The declarant buys its certificates from the competent authority in the EU Member State where it is established. A UAE company therefore has three options. It can sell to an EU buyer with this status. It can work through an indirect customs representative with authorised CBAM declarant status, who is then always the declarant. It can also set up its own EU company, such as a Dutch BV.

How exposed is the UAE to CBAM?

In 2025 the EU imported goods worth €9.3 billion from the UAE. Non-ferrous metals, the product group that includes aluminium, were 14.8% of this, and iron and steel 3.4% (European Commission, 2026). Aluminium, iron and steel are CBAM goods, and the definitive phase started on 1 January 2026.

Does the Netherlands have a tax treaty with the UAE?

Yes. The Netherlands and the United Arab Emirates maintain a double tax treaty. It covers income tax, wage tax, corporate tax and dividend tax on the Dutch side, and income and corporate tax on the Emirati side.

What should a UAE group consider when structuring a Dutch BV?

Under the tax treaty, the Dutch withholding tax on dividends to a UAE company is 5% from a 10% holding and 10% in other cases, and 0% on interest and royalties. The Dutch dividend exemption can bring dividends to a qualifying company shareholder in a treaty country to 0% from a 5% holding, within the anti-abuse rules. For 2026, the Dutch list of low-tax jurisdictions names Bahrain and leaves out the UAE. For owners in Bahrain and the UAE, our team checks the current list first. Plan the ownership chain before you set up the BV, with treaty protection and real business activity (substance).