Running a UK company from Dubai, Riyadh or Doha.
The 2026 operator's guide for Gulf-based founders — corporate tax realities post-2023, place of effective management, banking, UBO disclosure, and the treaty framework that decides who taxes what.
A UK Limited Company owned and directed by a Gulf-resident founder is one of the most powerful cross-border structures available today — but it is not the tax-free shell that WhatsApp forums still describe. Since June 2023 the UAE has a 9% Corporate Tax. Saudi Arabia has enforced a 20% CIT on foreign-owned business for years. Qatar sits on 10%. Each of these regimes reaches a UK Ltd whose place of effective management sits inside the jurisdiction — regardless of where the company is registered. Get the structure right and you pay UK Corporation Tax cleanly, draw dividends into a jurisdiction with zero personal income tax, and defend the position with a UK residency certificate. Get it wrong and you pay tax twice.
- A UK Ltd is always UK-resident for Corporation Tax — that never changes because you moved to Dubai.
- The UAE, Saudi Arabia and Qatar each have a real corporate tax regime with a Permanent Establishment concept that can reach your UK Ltd.
- Place of effective management is the pivot: if all decisions are taken from a Gulf desk, expect the local authority to notice.
- Personal income tax remains nil in all three jurisdictions on dividends from a foreign company — this is the genuine planning advantage.
- Banking a UK Ltd is done in the UK (Wise, Revolut, Barclays), not locally in the Gulf, unless you also hold a local trade licence.
- A UK tax residency certificate plus proper board-minute discipline is the cheapest, strongest defence you can build.
Why founders run UK companies from the Gulf
The pattern is now well-established. A founder moves to Dubai for the residency, the lifestyle and the zero personal income tax. Their clients — SaaS buyers, consulting principals, e-commerce marketplaces, agency retainers — are almost entirely in the UK, the EU and North America. Those clients want to be invoiced by a company they can look up on Companies House, paid into a GBP account they recognise, contracted under English law, and reconciled in a currency their finance team understands. A UAE mainland company or a RAK ICC offshore structure does not clear those tests as cleanly as a UK Ltd does.
The UK Limited Company sits in the middle of this diagram beautifully: cheap to run (£13 filing fee, £100 confirmation statement, no minimum capital, no in-person requirement), respected by Stripe and every EMI, and — for a Gulf-resident shareholder — capable of paying its after-tax profit out as a dividend that lands, personally, in a jurisdiction with zero personal income tax. Done correctly, this is not aggressive planning. It is a clean, transparent, treaty-supported structure that HMRC and the Gulf authorities can both reconcile.
The complications begin the moment the UK Ltd starts to look, from the Gulf side, like a locally managed business. That is where this guide focuses — because it is the question that actually decides whether the structure protects you or exposes you.
Three Gulf regimes, three different answers.
The Gulf is not a single tax jurisdiction. What is true in Dubai is not true in Riyadh, and Doha runs its own rules. A honest side-by-side.
- Corporate Tax
- 9% (from June 2023)
- Small-business relief
- AED 375,000 profit exemption
- PE concept
- Yes — Art. 14, FDL 47/2022
- UK DTAA
- In force 2018
The most common Gulf base for UK-Ltd founders. Zero personal income tax, world-class banking, Emirates ID + Ejari clears most KYC. But since 1 June 2023 the UAE has a 9% federal Corporate Tax that can reach a foreign-incorporated company managed from within the UAE.
- Corporate Tax
- 20% (non-GCC), 2.5% Zakat (GCC)
- Small-business relief
- No standard exemption
- PE concept
- Yes — Art. 4, Income Tax Law
- UK DTAA
- In force 2008
The Vision 2030 economy has pulled tens of thousands of foreign professionals into Riyadh, Jeddah and NEOM. ZATCA is the most aggressive Gulf tax authority on PE and transfer pricing. Running a UK Ltd from a Riyadh desk without local licensing is materially higher risk than doing the same from Dubai.
- Corporate Tax
- 10% (foreign-owned)
- Small-business relief
- No standard exemption
- PE concept
- Yes — Law 24/2018
- UK DTAA
- In force 2010
Qatar's tax base is narrower than the UAE's but the PE and 10% CIT regime is enforced. QFC-licensed entities sit under a separate 10% CIT and can be a legitimate onshore vehicle. For non-QFC founders, a UK Ltd operated from Doha carries the same substance questions as anywhere else in the region.
The UAE reality — post-2023 Corporate Tax
Federal Decree-Law No. 47 of 2022 introduced a 9% federal Corporate Tax on business profits, effective from financial years starting on or after 1 June 2023. The headline story is that UAE-licensed entities now file a UAE CT return. The lesser-told story is Article 11(3)(b), which treats a foreign juridical person as a UAE resident where it is "effectively managed and controlled in the State".
For a UK Ltd whose sole director sits at a desk in Business Bay, holds every board meeting in the UAE, signs every contract in the UAE, and takes every strategic decision in the UAE, this Article is a live risk. The Federal Tax Authority's Corporate Tax Public Consultation Document (April 2023) and subsequent Ministerial Decisions make clear that "effective management" is a substance test, not a paperwork test. Board minutes filed in Companies House that say the board met in London, when the director never left Dubai, are not credible.
The practical position we recommend: Gulf-based founders should treat their UK Ltd as UK-resident by documented practice — real UK board meetings (video-linked from London when possible, or scheduled during actual UK trips), UK-based professional advisors instructed on record, and a UK residency certificate obtained annually from HMRC. Where the founder cannot avoid running everything from Dubai, the honest answer is to model the UAE CT exposure explicitly and pay it — 9% on the UAE-attributable profit above AED 375,000 is not a punitive rate, and the UK–UAE Convention provides relief to prevent economic double taxation on the same income.
Saudi Arabia — ZATCA, PE and 20% CIT
Saudi Arabia is the Gulf jurisdiction founders most often underestimate. Under the Income Tax Law (Royal Decree M/1 of 2004 as amended), a non-Saudi-owned business pays 20% Corporate Income Tax; a GCC-national-owned business pays 2.5% Zakat instead. There is no headline rate as low as the UAE's and no small-business relief threshold to match.
The bigger issue for a UK-Ltd founder in Riyadh is Article 4, which defines Permanent Establishment along OECD lines but is enforced aggressively. ZATCA has publicly pursued PE reclassification cases against foreign contractors, consultants and technology vendors whose only Saudi presence was a single senior executive habitually concluding contracts on the ground. A UK Ltd sole director based in Riyadh, signing Saudi client contracts from a Riyadh desk, meets that threshold on its face.
The UK–Saudi Convention (signed 31 October 2007, in force 1 January 2009) provides treaty relief and caps Saudi withholding on outbound dividends at 5% and interest at 5%. But treaty protection is conditional on obtaining a UK residency certificate and being able to show the UK Ltd is not a Saudi PE. If ZATCA succeeds in classifying the UK Ltd as having a Saudi PE, treaty relief does not eliminate the 20% CIT on Saudi-source profit — it merely stops the same income being taxed twice.
Practical guidance: Founders serving Saudi clients from Riyadh should route Saudi-facing revenue through a licensed Saudi entity (a limited liability company or a branch registered with the Ministry of Investment) and keep the UK Ltd focused on non-Saudi clients. The two entities trade with each other at arm's length under transfer pricing rules and each pays tax where it should. Trying to invoice Saudi clients from a UK Ltd with no Saudi presence, from a Riyadh desk, is the highest-risk pattern in the region.
Qatar — GTA and the 10% CIT regime
Law No. 24 of 2018 replaced Qatar's earlier tax code and confirmed a 10% Corporate Income Tax on business profits attributable to Qatar. The General Tax Authority (GTA) administers it. A Qatari or GCC-owned entity pays no CIT on most local business (with defined exceptions), but a foreign-owned business — and a foreign company operating through a Qatari PE — pays 10%.
Qatar Financial Centre (QFC) entities sit under a separate regime with its own 10% CIT, a well-developed regulatory framework, and easier access to onshore-onshore contracting. For founders who plan to trade seriously with Qatari counterparties from Doha, a QFC licence is often the cleaner structure than a UK Ltd — especially given Qatar's requirement that most local contracts be entered into by a locally licensed entity.
The UK–Qatar Convention (signed 25 June 2009, in force 15 October 2010) allocates taxing rights on business profits, dividends, interest and royalties. Withholding on dividends can be reduced to 15%, on interest to 0%. Again, treaty relief follows evidence — a UK residency certificate, proper board minutes, and a defensible position on where the UK Ltd's central management sits.
Practical guidance: Founders in Doha whose client base is UK, EU or wider international operate a UK Ltd from Qatar much as their peers do from Dubai — with the same substance discipline. Founders whose client base is genuinely Qatari should look at a QFC licence rather than trying to invoice through a UK entity that has no local presence.
Corporate residence and place of effective management
The single most important concept in this whole guide is corporate residence. Under section 14 of the Corporation Tax Act 2009, a UK-incorporated company is UK-resident for tax. That much never changes. But under the case law of central management and control — De Beers Consolidated Mines v Howe (1906) and everything since — a company can be dual-resident in a second jurisdiction if its real decision-making happens there.
When a UK Ltd is dual-resident, the tiebreaker in each UK–Gulf treaty is place of effective management— the OECD-standard test that asks where key management and commercial decisions are, in substance, made. If POEM sits in the UAE, the UAE gets primary taxing rights and the UK gives credit. If POEM sits in the UK, the UK keeps primary taxing rights and the UAE gives up its claim.
In practice this is decided by evidence. Board minutes, calendar entries, travel records, email metadata, video-call logs, professional advisor engagement letters, banking location, contract signing location. A founder who spends 330 days a year in Dubai and holds one perfunctory "London board meeting" via Zoom while sitting in Business Bay is not credibly UK-managed. A founder who genuinely travels to London quarterly for board meetings, uses UK advisors, and takes major decisions in and from the UK is.
Our recommendation to Gulf-based clients is simple: pick a position and stay consistent with it. Either build enough UK substance to defend UK-only residence, or accept dual-residence and manage the second jurisdiction's tax filings openly. Ambiguity is the worst place to sit — it invites the local authority to define your position for you.
Banking a UK Ltd from Dubai, Riyadh and Doha
Gulf-based founders universally ask the same question first: where does the UK Ltd bank? The answer is almost always the UK, not the Gulf. UAE, Saudi and Qatari banks open accounts for locally-licensed entities, not for foreign companies whose only footprint is a director's residency visa.
The functional stack we see work:
- Primary: Wise Business or Revolut Business in the UK Ltd's name — opened remotely, GBP/EUR/USD balances, low-friction receipt of client payments.
- Secondary: Airwallex or Payoneer for multi-currency receipts, especially where the client insists on paying via local rails (USD ACH, EUR SEPA).
- Stripe: Stripe UK connected to the UK Ltd's Wise account — the fastest path to online card acceptance.
- High-street tier: Barclays, HSBC or Lloyds — pursued once trading is visible (usually after 6–12 months of Wise/Revolut activity). This is the tier that closes serious enterprise procurement portals.
Founders' personal accounts remain local: Emirates NBD or Mashreq in the UAE, Riyad Bank or Al Rajhi in Saudi Arabia, QNB or Doha Bank in Qatar. Dividends flow from the UK Ltd's UK account to the founder's personal Gulf account by international transfer. The two flows must never mix. We spend more time repairing broken corporate-veil evidence than almost any other issue.
No advisor can guarantee bank or EMI approval. Onboarding decisions are made by the provider's underwriting team on a case-by-case basis. What we do — in every Gulf-founder file — is prepare the application so the business rationale, KYC, source-of-funds and expected volumes are legible to a first-line reviewer. OurBanking Readiness service exists for exactly this workflow.
Invoicing, VAT and cross-border reality
Your UK Ltd invoices under UK VAT rules. For B2B services to business customers outside the UK, the general place-of-supply rule (VAT Act 1994, Schedule 4A) places the supply where the customer belongs — which usually means no UK VAT charged, and the customer accounts for local reverse-charge VAT (in the EU) or nothing (in the US, Gulf, most of Asia).
Practical rules for a Gulf-based UK-Ltd founder:
- Register for UK VAT voluntarily if you invoice UK-VAT-registered customers who can reclaim, or if your international revenue is high enough that VAT recovery on UK costs matters. Our voluntary VAT guide covers the decision framework.
- UAE VAT at 5% applies where you have a fixed establishment in the UAE. A UK Ltd with no UAE presence typically stays outside UAE VAT — but if the UK Ltd has a UAE-licensed branch, it registers with the FTA.
- Saudi VAT at 15% (raised in July 2020) applies to supplies made in-Kingdom. A UK Ltd selling into Saudi Arabia without a local establishment generally does not register for Saudi VAT, but the customer accounts for reverse charge.
- Qatari VAT has been discussed for years but is not yet implemented at time of writing (July 2026). Expect a 5% rate when it lands, harmonised with the GCC VAT Framework Agreement.
- Invoice wording matters. A UK Ltd invoice should show the company number, registered office, GB VAT number (if registered), and — for zero-rated exports of services — a note stating the reverse-charge basis. Banks and enterprise procurement portals read these fields.
The cleanest structures we see work
Three patterns cover the majority of successful Gulf-based UK-Ltd founders.
Solo founder in Dubai. Clients in the UK, EU and North America. Revenue £150k–£600k. UK Ltd owned 100% by the founder, sole director, banked with Wise Business and Barclays. Pays 19–25% UK Corporation Tax. Dividends extracted quarterly to a personal UAE account. Founder holds a UAE freelance permit or Golden Visa purely for residency. No UAE mainland licence — the UK Ltd does all invoicing. Total annual compliance cost: under £2,000.
Founder based in Riyadh or Doha with a mixed client base. UK Ltd invoices non-Gulf clients, is UK-tax-resident, banks in the UK. A parallel Saudi LLC or QFC entity invoices Gulf clients locally, pays Saudi/Qatari CIT on that revenue, and holds the local trade licence. The two entities operate at arm's length; intra-group services (if any) are documented under transfer pricing. This is the "clean split" structure — more paperwork, but bulletproof.
UK Ltd holding a Stripe UK account, a UK VAT registration, a UK EORI, and a UK VBA or fulfilment address. Founder in Dubai manages operations remotely. Inventory in a UK 3PL or in an EU fulfilment centre under IOSS. This structure is banking-friendly, VAT-clean, and lets the founder use the UK Ltd as a pan-European trading vehicle from the UAE. Our EORI Registration and VAT Registration services are used by most of these clients.
UK compliance you still have to file
Living in the Gulf does not exempt you from any UK filing. The annual calendar for a Gulf-based UK Ltd is identical to a London-based one:
- Confirmation statement — annually, £34 online, current officers, PSCs, SIC and shareholders confirmed.
- Annual accounts — filed at Companies House within 9 months of the accounting reference date.
- Corporation Tax return (CT600) — filed with HMRC within 12 months of period end; tax due within 9 months and 1 day.
- PSC updates — filed within 14 days of any change.
- Companies House identity verification — mandatory since April 2025; see our Identity Verification service.
- VAT returns — quarterly if registered.
- UK tax residency certificate — annual renewal from HMRC; the single most useful document for defending your position against any Gulf authority.
Mistakes that quietly cost founders their structure
Written and reviewed by senior advisors
Twelve years advising cross-border founders on UK structures. Regularly instructed by clients in Dubai, Riyadh, Doha, Muscat and Kuwait City on incorporations, banking readiness and tax residency defence.
ICAEW-qualified. Reviews every tax-adjacent article for factual accuracy against the current UK Corporation Tax framework, the UAE Corporate Tax regime, and the UK–UAE, UK–Saudi and UK–Qatar double tax conventions.
This article is general guidance, not tax advice for your specific circumstances. Tax residence, PE analysis and treaty positions depend on facts we can only assess in a direct engagement. Speak to an advisor before implementing any structure described above.
FAQ — running a UK Ltd from the Gulf
Can I own and run a UK Limited Company while living in Dubai, Riyadh or Doha?+
Yes. The UK places no restriction on foreign ownership, foreign directors or foreign residency of the officers of a UK Limited Company. Founders based in the UAE, Saudi Arabia and Qatar routinely own 100% of a UK Ltd, act as sole director and PSC, and operate the company entirely remotely. What changes is the tax and disclosure position in your country of residence — not your ability to hold the UK structure.
Does my UK company become taxable in the UAE just because I run it from Dubai?+
Potentially, yes. Since 1 June 2023 the UAE has operated a 9% Corporate Tax regime under Federal Decree-Law No. 47 of 2022. A UK Ltd whose 'place of effective management' sits in the UAE — because the sole director signs, negotiates and manages everything from a Dubai desk — can be treated as a UAE resident entity under Article 11(3)(b), or trigger a Permanent Establishment for the UK company inside the UAE under Article 14. That does not remove your UK Corporation Tax obligation; it can add a UAE one on top, offset (in most cases) under the UK–UAE double tax convention. The right answer depends on substance, contracts and where decisions are documented as being taken.
What about Saudi Arabia? Is running a UK company from Riyadh a tax issue?+
Saudi tax is more complex than the UAE headline suggests. ZATCA (the Zakat, Tax and Customs Authority) applies a 20% Corporate Income Tax to non-GCC-owned entities and a Permanent Establishment concept under Article 4 of the Income Tax Law. A UK Ltd managed day-to-day from Riyadh can create a PE, bringing the Saudi-source profits into a 20% CIT charge and 5% withholding on outbound service fees. GCC nationals face Zakat at 2.5% instead. The UK–Saudi DTAA (in force since 2008) provides relief on double taxation but does not automatically override PE rules.
And Qatar — does the same apply to founders in Doha?+
Qatar's General Tax Authority (GTA) applies a 10% Corporate Income Tax to foreign-owned entities under Law No. 24 of 2018. Like Saudi Arabia, Qatar recognises a Permanent Establishment where a UK Ltd is effectively managed from Doha or where a dependent agent habitually concludes contracts there. Qatar Financial Centre (QFC) and Qatar Free Zones sit under a separate regime. The UK–Qatar DTAA (in force since 2010) provides treaty relief but, again, requires you to structure and evidence substance correctly.
Do I still pay UK Corporation Tax if I live in the Gulf?+
Yes. A UK-incorporated company is UK-resident for Corporation Tax purposes under section 14 CTA 2009, regardless of where the director sits. You file annual accounts at Companies House and a CT600 with HMRC, paying 19% on profits up to £50,000, tapered marginal relief up to £250,000, and 25% above. The question is never whether you owe UK CT — it is whether you also owe tax in your Gulf jurisdiction on the same profits, and how the treaty resolves it.
Can I take profits out of the UK company tax-free by living in the UAE?+
There is no personal income tax on individuals in the UAE, Saudi Arabia or Qatar on salaries and dividends received from a foreign company. That is the genuine planning advantage. However, since 2023 the UAE has extended Corporate Tax to certain natural persons carrying on a business, and Saudi Arabia treats dividend flows into resident structures under specific rules. Dividends themselves are not withholding-taxable in the UK when paid out. The clean approach is a UK Ltd paying UK Corporation Tax on profits, then dividending the after-tax profit to a Gulf-resident shareholder who receives it personally free of Gulf personal tax — provided no PE, no place-of-effective-management and no UAE Corporate Tax trigger sits underneath.
Will the UK company need to disclose me as a UBO in the Gulf?+
You should assume yes. The UAE's Cabinet Decision No. 58 of 2020 introduced UBO disclosure at mainland and most free-zone registrars. Saudi Arabia's Commercial Register reforms (2022 onwards) require beneficial ownership disclosure for any entity operating locally. Qatar's Law No. 1 of 2020 mirrors the FATF standard. If your UK Ltd has no physical footprint in the Gulf jurisdiction, direct UBO filing there may not apply — but the moment you take a local trade licence, an economic substance filing, a bank account, or a service agreement between the UK Ltd and a local entity, disclosure obligations attach.
Can I bank the UK Ltd in the UAE, Saudi Arabia or Qatar?+
Local banking of a foreign company is possible but rarely straightforward. UAE banks (Emirates NBD, Mashreq, ADCB, RAKBANK, Wio) will open a UAE account for a UK Ltd only if you also hold a UAE Trade Licence or a real operational footprint. Without that, the practical route is a UK-based fintech stack (Wise Business, Revolut Business, Airwallex) held in the UK Ltd's name, operated from Dubai. Saudi and Qatari banks generally will not onboard a foreign entity without a local branch registration. For most Gulf-based founders the correct structure is: UK Ltd banked in the UK; personal account held locally in the Gulf where you live.
What about VAT — do I charge UAE, Saudi or Qatari VAT to my clients?+
Your UK Ltd charges VAT based on UK rules and the place-of-supply of its services, not where you personally sit. For B2B services to overseas business customers, the general rule places supply outside the UK — no UK VAT — but you may still need to register in the customer's jurisdiction under reverse-charge or e-services rules. UAE VAT at 5% (Federal Decree-Law No. 8 of 2017), Saudi VAT at 15% (raised in 2020) and Qatari VAT (not yet in force at time of writing) apply where your UK Ltd has a fixed establishment or exceeds registration thresholds in-country. In practice most Gulf-based UK Ltds selling internationally register for UK VAT only, and stay outside GCC VAT nets.
Do I need a UK registered office if I live in the Gulf?+
Yes. Every UK Limited Company must maintain a registered office in the UK jurisdiction of incorporation (England & Wales, Scotland or Northern Ireland). You cannot use your Dubai villa, Riyadh apartment or Doha office as the registered office of an English company. Since ECCTA 2024 the address must be a genuine 'appropriate address' where documents can be signed for — a UAE PO Box or a Saudi Iqama address does not qualify. This is why our £59/year registered office and £35/year director service address exist.
How does Companies House identity verification work if I am in the Gulf?+
Since April 2025 all UK directors and PSCs must complete Companies House identity verification. Non-residents in the Gulf verify through an Authorised Corporate Service Provider (ACSP) remotely — a video-KYC session and a document check, followed by Companies House issuing a personal code directly to the individual. Passport, plus a Gulf proof of address (utility bill, Ejari, Emirates ID, Iqama, Qatar ID), is generally accepted. No travel to the UK is required.
Do I need Economic Substance filings in the UAE for my UK Ltd?+
The UAE's Economic Substance Regulations (ESR) apply to UAE-licensed entities carrying on 'relevant activities', not to foreign companies whose only nexus to the UAE is their director's residence. If your UK Ltd holds no UAE trade licence, ESR filings are not triggered. If you later take a mainland or free-zone licence and use it to invoice or hold IP, ESR becomes relevant.
Is a UK Ltd better than a Dubai free-zone company for a solo founder?+
It depends on where your clients are, where you bank, and how you draw personal income. A UK Ltd is superior for invoicing UK, EU and North American clients — it clears bank underwriting, Stripe, and enterprise procurement portals faster than a Dubai free-zone entity. A Dubai free-zone company is superior for GCC-facing trade, visa sponsorship, and local licensing. Many mature founders eventually run both, with the UK Ltd as the international invoicing vehicle and a Gulf entity as the residency/visa vehicle.
What is the cleanest structure for a Dubai-based consultant with UK and EU clients?+
The pattern we see most often: a UK Limited Company owned 100% by the founder, banked with a UK fintech (Wise or Revolut Business) plus a UK high-street account once trading is visible, invoicing clients in GBP/EUR/USD, paying UK Corporation Tax on profits, then dividending after-tax profit to the Dubai-resident shareholder. In parallel the founder holds a UAE residency visa via a small free-zone licence or Golden Visa, giving them personal Gulf tax residency and a local bank account. The two structures are legally separate; the money flow is transparent to both sides.
Does the UK–UAE, UK–Saudi or UK–Qatar double tax treaty help me?+
Yes, when correctly applied. The UK–UAE Convention (signed 2016, in force 2018) allocates taxing rights over business profits, dividends, interest and royalties. The UK–Saudi Convention (2007/2008) similarly restricts source-country tax on dividends and interest. The UK–Qatar Convention (2009/2010) does the same. In each case, treaty relief is not automatic — you claim it, on evidence, usually by lodging a residency certificate. A UK-resident company with a Gulf-resident director should almost always secure a UK residency certificate from HMRC (form CISC9 / online request) to defend against Gulf-side reclassification.
What are the biggest mistakes founders make running a UK Ltd from the Gulf?+
The five we fix most often: (1) treating the UK company as 'offshore' when in reality it pays UK Corporation Tax; (2) ignoring UAE Corporate Tax post-2023 on the assumption the Gulf is still tax-free; (3) using a home address in Dubai as the registered office — non-compliant and non-appropriate under ECCTA; (4) invoicing local Gulf clients through the UK Ltd without a licence, triggering Permanent Establishment questions; (5) mixing personal and company money because there is no local bank account, breaking the corporate veil.
Structure your UK company for a life based in the Gulf.
We work with founders in Dubai, Abu Dhabi, Riyadh, Jeddah, Doha, Muscat, Manama and Kuwait City every week. Book a confidential call to structure yours correctly from the start — or repair one that has drifted.
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