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A Firmer Foothold in the UAE: New Rights for Russian Businesses
6 min 43 sec
September 24, 2026 (Edited)
Written by
i.gorchakov@tamimi.com 
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Bilateral economic relations between the United Arab Emirates (“UAE”) and the Russian Federation (“Russia”) have expanded rapidly and exponentially in the recent years. In 2025, bilateral non-oil trade reached US$20.4 billion, representing a 77.7% increase over 2024 and almost double the US$10.8 billion recorded in 2022. Public reporting identifies fintech, healthcare, transport, logistics and professional services as priority sectors for deeper cooperation.
Against this backdrop, the entry into force of the Agreement on Trade in Services and Investment between the Government of the Russian Federation and the Government of the United Arab Emirates (“TISIA” or the “Agreement”) is timely. Signed in Moscow on 8 August 2025, the Agreement has now entered into force as of August 2026.
The Agreement establishes a free trade area covering services and investment. It complements the broader architecture for UAE-Russia economic relations. Together with the 2025 Economic Partnership Agreement between the UAE and the Eurasian Economic Union (“EAEU”), the TISIA now provides a comprehensive framework covering trade in goods, services and investment, facilitating all of them significantly, signalling a bright green light for the Russian capital to flow into the UAE at an even faster pace.
A New Layer in the Existing Treaty Framework
The TISIA builds on several international and bilateral instruments already existing between Russia and the UAE.
First, the Agreement establishes its free trade area in accordance with Article V of the General Agreement on Trade in Services (“GATS”). It adopts the familiar GATS architecture of market access, national treatment, most-favoured-nation treatment and schedules of specific commitments. The Agreement is therefore best understood as a bilateral liberalisation instrument that goes beyond the Parties’ existing World Trade Organization (“WTO”) commitments in selected sectors and opens doors between Russia and UAE specifically that are not otherwise open to other participants of the WTO.
Second, it complements the 2025 Economic Partnership Agreement with the EAEU. While that agreement principally liberalises trade in goods, the TISIA addresses the services and investment components of the relationship. The two instruments collectively seek to create a comprehensive free trade framework.
Third, the Agreement expressly reaffirms the 2010 Agreement between Russia and the UAE on the Promotion and Reciprocal Protection of Investments (“BIT”) and records the Parties’ willingness to improve it. The distinction matters. The TISIA’s investment chapter is primarily facilitative and institutional. It does not replace the BIT or introduce a new investor-State dispute settlement mechanism.
The TISIA also forms part of a recently expanded bilateral tax framework. The UAE and Russia signed a new agreement for the avoidance of double taxation on income and capital on 17 February 2025, which entered into effect on 1 January 2026. The new tax treaty applies to private companies and individuals and generally caps withholding tax on dividends, interest and royalties at 10%, subject to applicable conditions. By reducing the risk of double taxation, it therefore complements the TISIA by reducing tax barriers to cross-border services, financing and investment.
Asymmetric Liberalisation, Reflecting Asymmetric Demand
One of the Agreement’s most notable features is the asymmetry of the Parties’ specific commitments.
Public reporting on the Agreement indicates that the UAE has undertaken commitments in 64 services subsectors beyond its existing WTO commitments, while Russia has opened 12 additional subsectors. Russian service suppliers therefore obtain materially broader additional access to the UAE market than UAE suppliers obtain in Russia.
This imbalance appears to reflect the existing direction of commercial demand and capital flows. The UAE has increasingly served as a base for businesses seeking access to the Middle East, Central Asia, Africa and the Indian subcontinent. Russian businesses, in particular, have established a growing presence in the UAE, using it as a regional headquarters, financing centre and logistics platform to serve these markets.
The greater degree of liberalisation granted by the UAE can therefore be seen as commercially responsive to prevailing patterns of bilateral trade and investment. The Agreement formalises this dynamic while providing reciprocal, although not numerically identical, commitments.
This asymmetry may also reinforce the UAE’s broader role as a services and logistics hub for cross-border commerce between Eurasia and markets to the south and east. The Agreement’s express reference to cooperation on the international North–South Transport Corridor further supports this function.
Where the Agreement Opens the Doors
For Russian service providers, certain sectors are opened without the restrictions previously applicable. The principal beneficiaries include providers of computer services, research and development, technical testing and analysis, technical consultancy, air transport reservation services, ship and aircraft repair services, passenger and freight rail transport, management services, educational services and legal services.
In these sectors, Russian companies may hold 100% of the capital of UAE entities, subject to the applicable schedule and domestic licensing requirements. Russian investors may also establish entities with 100% Russian capital in designated UAE free zones in certain banking, healthcare and news agency activities. In other identified sectors, including complex engineering services, medical and dental services, the rental of vessels or other transport equipment without operators, and maritime passenger transport, Russian direct participation may reach the significant 70%.
The effect may extend beyond the service suppliers themselves. More accessible financial, logistics, technical and professional services can lower the transactional costs associated with bilateral trade in goods. The TISIA could therefore operate as the services infrastructure supporting the tariff liberalisation achieved through the UAE–EAEU agreement.
From Market Access to Domestic Regulation
The Agreement does more than list sectors. It creates a set of disciplines governing how the Parties regulate services covered by their commitments.
Under Article 4.5, a Party must provide the market access specified in its schedule. Unless expressly reserved, it may not impose limitations such as numerical quotas, monopolies, economic-needs tests, restrictions on the total value or quantity of services, caps on relevant personnel, prescribed forms of legal entity or limits on foreign capital participation. Article 4.6 separately requires national treatment in scheduled sectors, subject to the qualifications recorded in each Party’s schedule.
Article 4.10 is particularly relevant to businesses operating in regulated sectors. It requires measures of general application to be administered reasonably, objectively and impartially. Qualification requirements, technical standards and licensing procedures must be based on objective and transparent criteria and must not be more burdensome than necessary to ensure the quality of a service. Competent authorities must also provide information concerning application requirements, fees, technical standards, review procedures and indicative processing periods.
These obligations may improve predictability, but they do not eliminate domestic regulation. Market access under an international treaty is not equivalent to the automatic conferral of a domestic licence.
A Russian company entitled to establish a wholly owned UAE entity must still comply with the relevant UAE federal and emirate-level requirements, free-zone rules, licensing conditions, professional qualification requirements and sector-specific approvals. The same applies to UAE businesses entering the Russian market.
Institutional Routes for Removing Obstacles
The TISIA creates two institutional bodies that may be important in its practical implementation.
Under Articles 3.3 and 3.4, the Parties are to establish a Russian Federation-UAE Council on Investment. The Council is tasked with monitoring investment relations, identifying opportunities for expansion, consulting on ways to enhance investment flows and working towards the removal of impediments to bilateral investment. It may also directly seek the views of the private sector actors. A Party can refer a specific investment matter to the Council through a written request describing the obstacle concerned.
This gives businesses a potentially valuable channel reducing formalities otherwise present if an obstacle is tried to be dealt with via foreign local authorities. Private parties do not appear to have standing to bring claims directly before the Council. They may, however, raise regulatory or practical obstacles with their government, which may then place the issue before the Council. This is in accord of the declared national treatment: commercial parties may appeal to their own national authorities, which will then have a direct recourse to deal with the issue with the corresponding foreign representatives.
The Agreement also establishes a Joint Committee meant to convene every 2 years with broader State-level responsibility for supervising the operation and implementation of the Agreement.
These bodies could provide a pragmatic route for resolving obstacles affecting capital flows or services trade before they develop into formal inter-State disputes.
Written by
The TISIA opens doors that were previously closed or only partly open, including routes to full foreign ownership in certain sectors.
Not Everything Is Liberalised
The Agreement contains material carve-outs.
Its services chapter does not apply to government procurement, subsidies, grants and other forms of State support. It also excludes measures governing access to the permanent employment market and measures concerning citizenship, permanent residence or permanent employment. Air traffic rights and services directly related to their exercise are generally excluded, subject to specified exceptions for aircraft repair and maintenance, sales and marketing, computer reservation systems, airport operation and management, and ground-handling services.
Governmental services supplied neither commercially nor in competition with other suppliers fall outside the definition of “services”. The Agreement also preserves general exceptions for public morals, public order, health, safety, privacy and compliance with domestic law, as well as broad security exceptions. Restrictions may additionally be introduced in response to serious balance-of-payments and external financial difficulties, if certain conditions are met.
Concluding Remarks
For businesses, the central takeaway of the Agreement is largely twofold. The Agreement opens doors that were previously closed or only partly open, including routes to full foreign ownership in certain sectors. However, walking through those doors will still require careful attention to the specific commitments undertaken in the schedules to the TISIA, local sector-specific regulation and the wider legal environment in both Parties. With careful planning and appropriate local advice, businesses can convert these new rights into meaningful commercial opportunities.
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