Both the United Arab Emirates and Singapore are members of WIPO's Madrid System (the Madrid Protocol), so a brand based in either country can file at home once and then extend that filing to other member countries through a single international application. This guide explains how that works from each side, where a qualified local attorney is still needed, and when a direct national filing is the better call.
What Membership of WIPO's Madrid System Gives You
WIPO's Madrid System is an administrative route, not a global trademark. It gives you one application, filed in one language, paid in one currency, that produces an international registration at WIPO. In that application you choose the member countries you want protection in, and the office in each of those countries then examines your trademark under its own national law.
Singapore is a long-standing member. The United Arab Emirates is a more recent member, which is why a lot of brand owners there are only now looking at the route. Check the current member list on WIPO before you count on covering a country.
The advantages are administrative, and they add up at portfolio scale:
- One filing instead of one per country, with one set of paperwork.
- One renewal date for the whole international registration, every ten years.
- Changes of owner name, address, or ownership recorded once at WIPO rather than country by country.
- Countries and regions added later, on the same registration.
What it does not give you is a lighter examination. The office in every country you choose still applies its own rules on distinctiveness, classification, and conflicts with earlier trademarks.
Step One: Your Home Office and Your Home Trademark
You can only use WIPO's Madrid System through an office where you have a genuine connection: nationality, domicile, or a real and effective industrial or commercial establishment. For a company in the United Arab Emirates that home office is the Ministry of Economy. For a Singapore company it is IPOS.
You also need a home trademark at that office, either a pending application or a granted registration. WIPO calls it the basic mark. The international application has to match it. Same owner, same trademark, and a list of goods and services that is the same as the home list or narrower. You can never go broader through WIPO than you went at home.
That makes the home filing the most important drafting decision in the whole exercise. A home specification written too narrowly caps every country you later add. Written too broadly, it invites refusals in the stricter examining offices downstream and can weaken the home trademark itself. Get the home list right before you send anything to WIPO. Our guides on filing under UAE Law 36 of 2021 and on using Singapore as an ASEAN base go into what each office expects at that stage.
Step Two: The International Application and WIPO's Review
The international application goes to WIPO through your home office, which certifies that it matches the home trademark. WIPO then reviews it on formal grounds only: classification, the trademark's representation, the owner details, and whether the fees have been paid. If something is wrong, WIPO issues an irregularity notice with a deadline to fix it.
Fees have three parts: a basic fee, supplementary fees where you go beyond the included classes, and a fee for each country you choose. The fee for each country varies a lot because many members set their own individual fee instead of the standard complementary fee. WIPO publishes a fee calculator that gives you the exact figure for a given combination of countries and classes, so price your list there before you commit to it.
Once WIPO is satisfied, the trademark is recorded in the International Register and published in the Gazette, and the office in each country you chose is notified.
Step Three: National Examination and Provisional Refusals
This is the part people underestimate. The office in any country you chose can refuse your trademark, in whole or in part, for any reason it could have refused a direct national application: descriptiveness, a conflicting earlier trademark, an unacceptable specification, or an absolute ground under local law.
The office notifies WIPO, WIPO forwards the notice to you, and the clock starts. Under the system's rules, each office has twelve months to issue a provisional refusal, or eighteen months where that country has declared the longer period, and many have. Check the current declaration for each office on your list before you diarize anything, because the deadline for your response is set by that country's national rules and not by WIPO.
Responding is a national procedure. In practice that means:
- You answer under the law of the country that issued the refusal, in that country's format and language.
- Most offices require a qualified local attorney with a local address for service before they will accept a response. So the WIPO route spares you a local attorney at filing, then brings one in the moment there is an objection.
- Missing the response deadline usually means protection is refused in that country, even though the international registration itself survives everywhere else.
Budget for this. A country that accepts your trademark without objection costs you nothing after filing. A refusal needs a qualified local attorney and a substantive response, and refusals are common in the offices with strict specification practice.
Step Four: The Five-Year Dependency
For five years from the date of the international registration, your registration depends on the home trademark. If the home trademark is refused, withdrawn, or canceled in that period, the international registration falls with it for the affected goods and services in every country it covers. This is often called central attack.
There is a remedy. Within three months you can transform the protection in each affected country into a national application there, keeping the original date. It works, but it is expensive, because you are then paying government fees and qualified local attorneys in every country at once.
The practical response is to make sure your home trademark is solid before you build on it. If your home application is likely to draw an objection, it can be worth waiting for it to register before filing internationally.
WIPO's Madrid System or a direct national filing?
An international application through WIPO is the better route when you want several countries at once, when your specification is straightforward, and when central administration of renewals and ownership changes matters to you.
A direct national filing is often better when:
- You only want one or two countries, where one international application adds little.
- The target country has strict or unusual specification practice and you want the wording drafted locally from the start rather than defended after a refusal.
- Your home trademark is shaky, and you would rather not expose a portfolio to the dependency period.
- You need speed in one particular country and local prosecution is faster than the WIPO notification cycle.
Most portfolios end up mixed: an international application for the broad sweep, direct filings for the two or three countries that matter most or examine hardest.
If the United States Is on Your List
The United States is a country many filers from the United Arab Emirates and Singapore want to cover, and it has its own rules whichever route you take.
An owner whose domicile is outside the United States must be represented at the USPTO by an attorney licensed in the United States. That applies to an international registration that covers the United States exactly as it applies to a direct filing. A GTC attorney licensed in the United States acts as counsel of record for our clients, so that requirement is covered.
The United States also requires evidence of actual use in United States commerce before the registration is maintained, and a declaration of use between the fifth and sixth years after registration. The USPTO fee for that maintenance filing is $325 per class. If you decide to file directly at the USPTO rather than cover the United States through WIPO, the USPTO fee is $350 per class for the single base application. Our United States trademark page covers that route, and pricing sets out our professional fees for both.
Where to Start
Get the home trademark right, price your country list on WIPO's calculator before you shortlist countries, and set aside a working budget for provisional refusals in the two or three countries most likely to raise one. If you want the home filing, the international application, and the refusal responses handled as one piece of work, that is what our International Trademark Application via WIPO service does.
