United Arab Emirates

United Arab Emirates
Overview
Last reviewed - 04 September 2023
The United Arab Emirates (UAE), located in the southeast of the Arabian Peninsula, is
bordered by the Persian Gulf to the north, Oman to the east, and Saudi Arabia to the
south and west. It is a constitutional federation of seven Emirates: Abu Dhabi, Dubai,
Sharjah, Ajman, Umm Al-Quwain, Ras Al-Khaimah, and Fujairah. The federation was
formally established on 2 December 1971, and the capital is Abu Dhabi. Arabic is the
official language of the United Arab Emirates, with English widely spoken and used in
business, and the currency is the United Arab Emirates dirham (AED).
The United Arab Emirates has a well-established infrastructure, a stable political

system, and one of the most liberal trade regimes in the Gulf region. It continues to be
increasingly important, relevant, and attractive to businesses from around the world as
a place to do business and as a hub for the region and beyond. The United Arab Emirates
is also one of the best examples in the region of an economy that has successfully moved
away from reliance on the energy sector. A significant proportion of the gross domestic
product (GDP) is derived from non-oil revenues.
PwC has been practicing in the United Arab Emirates for over a quarter of a century and
specializes in audit, assurance, business advisory services, and tax and legal services.
Complementing our depth of industry expertise and breadth of skills is our sound
knowledge of the local business and regulatory environments across the Middle East.
Quick rates and dates

Corporate income tax (CIT) rates
Headline CIT rate (%) 9
Corporate income tax (CIT) due dates
Under the UAE CT Law, all taxable persons are

CIT return due date required to file a corporate tax return within nine
months from the end of the relevant tax period.
Under the UAE CT Law, all taxable persons are

CIT final payment due date required to pay corporate tax within nine months from
the end of the relevant tax period.
CIT estimated payment due Under the UAE CT Law, there is no requirement of
dates estimated/advance tax payments.
Personal income tax (PIT) rates
Headline PIT rate (%) NA
Personal income tax (PIT) due dates
PIT return due date NA
PIT final payment due date NA
PIT estimated payment due dates NA
Value-added tax (VAT) rates
Standard VAT rate (%) 5
Withholding tax (WHT) rates
WHT rates (%) 0% WHT in case of certain categories of UAE-sourced

(Dividends/Interest/Royalties) income to be specified by way of a Cabinet decision.
Capital gains tax (CGT) rates
Headline corporate capital gains Same as UAE CT rates, where participation

tax rate (%) exemption is not available.
Headline individual capital gains

tax rate (%) NA
Net wealth/worth tax rates
Headline net wealth/worth tax rate

(%) NA
Inheritance and gift tax rates
Headline inheritance tax rate (%) NA
Headline gift tax rate (%) NA
NA stands for Not Applicable (i.e. the territory does not have the indicated tax or
requirement)
NP stands for Not Provided (i.e. the information is not currently provided in this chart)
All information in this chart is up to date as of the 'Last reviewed' date on the
corresponding territory Overview page. This chart has been prepared for general
guidance on matters of interest only and does not constitute professional advice. You
should not act upon the information contained in this chart without obtaining specific
professional advice. No representation or warranty (express or implied) is given as to
the accuracy or completeness of the information contained in this chart, and, to the
extent permitted by law, PwC does not accept or assume any liability, responsibility, or
duty of care for any consequences of you or anyone else acting, or refraining to act, in
reliance on the information contained in this chart or for any decision based on it.
Corporate - Significant developments

There is a growing trend of tax reforms in the Middle East region, and the United Arab
Emirates (UAE) has implemented excise tax, value-added tax (VAT), and economic
substance regulations in October 2017, January 2018, and April 2019, respectively.
Country-by-country (CbC) reporting was also implemented in April 2019.
On 31 January 2022, the UAE Ministry of Finance (MoF) announced the introduction of a
federal corporate tax (CT) in the United Arab Emirates that will be effective for financial
years starting on or after 1 June 2023. On 3 October 2022, the Federal Decree-Law No.
47 of 2022 on the Taxation of Corporations and Businesses (‘UAE CT Law’) was signed.
UAE CT will be applicable across all Emirates and will apply to all business and
commercial activities, subject to certain exceptions. Transfer Pricing rules and
documentation requirements are also introduced as part of the UAE CT regime. The
Federal Tax Authority (FTA) will be responsible for the administration, collection, and
enforcement of CT.
Economic substance regulations

On 30 April 2019, the UAE MoF issued economic substance regulations ('Regulations'),
which were followed by the amended Regulations on 1 September 2020 introducing a
requirement for certain juridical persons (persons with separate legal personality) and
unincorporated partnerships that carry on a relevant activity in the United Arab
Emirates ('UAE licensees') to have adequate 'economic presence' in the United Arab
Emirates, relative to the activities they undertake.
It is currently unclear what impact the proposed UAE CT regime will have on the
economic substance requirements in the United Arab Emirates, especially in relation to
entities subject to CT at the 9% rate.
See Economic substance requirements in the Other issues section for more information.
Corporate - Taxes on corporate income

Under the Emirate-level tax decrees, income tax is payable under a progressive rate
system, with rates up to 55%. However, in practice, these tax decrees have not been
applied. Instead, branches of foreign banks are subject to income tax at a flat rate of
20% under separate Emirate-level bank decrees. Companies engaged in UAE oil and gas
and petrochemical activities are subject to income tax at varying rates under their
individual UAE concession agreements or fiscal letters.
The Federal UAE CT Law, which is effective for each taxable person’s new financial year
beginning on or after 1 June 2023, will be applicable across all Emirates and will apply
to all business and commercial activities, except to the following exempt persons
(subject to conditions):
• UAE government entity.

• UAE government-controlled entity.
• Person engaged in an extractive business in the United Arab Emirates.
• Person engaged in a non-extractive natural resource business in the United Arab
Emirates.
• Qualifying public benefit entity.
• Qualifying investment fund.
• Public pension or social security fund, or a private pension or social security
fund that is subject to regulatory oversight of the competent authority in the
state and that meets any other conditions that may be prescribed by the
Minister.
• Juridical person incorporated in the state that is wholly owned and controlled by
certain exempt persons.
• Any other person as may be determined in a decision issued by the Cabinet at the
suggestion of the Minister.
UAE CT will be applicable at the following rates:
Taxable income UAE CT rate (%)
• Taxable income not exceeding 375,000 UAE dirham

(AED).
• Qualifying income of a Qualifying Free Zone Person 0
(QFZP). *
• Taxable income exceeding AED 375,000.

• Non-qualifying income of a QFZP. 9
* Please refer to Free trade zones (FTZs) in the Tax credits and incentives section.
Corporate - Corporate residence

Historically, UAE corporate tax residence has been certified by UAE tax authorities
based on several documents submitted for UAE-incorporated legal entities only, both in
the mainland and in Free Zones.
Under the UAE CT Law, companies and other juridical persons that are incorporated or
otherwise formed or recognized under the laws of the United Arab Emirates will be
considered resident persons. This covers juridical persons incorporated in the United
Arab Emirates under either mainland legislation or applicable Free Zone regulations.
Foreign companies and other juridical persons may also be treated as resident persons
for CT purposes where they are effectively managed and controlled in the United Arab
Emirates.
A non-resident person, which is a UAE taxable person, is a person who is not considered
a person and either:
• has a permanent establishment (PE) in the United Arab Emirates

• derives state-sourced income, or
• has nexus in the United Arab Emirates by way of earning income from
immovable property in the United Arab Emirates.
Permanent establishment (PE)

Under the UAE CT Law, the definition of a PE is aligned with the definition in the
Organisation for Economic Co-operation and Development (OECD) Model Tax
Convention.
In terms of the UAE CT law, a non-resident person would generally be considered to

have a PE in the United Arab Emirates where:
• it has a fixed or permanent place in the United Arab Emirates through which the
business of the non-resident person, or any part thereof, is conducted.
• where a person has and habitually exercises the authority to conduct a business
or business activity in the United Arab Emirates on behalf of the non-resident
person (this means either the person habitually concludes contracts in the name
of the non-resident person or the person habitually negotiates contracts that are
concluded by the non-resident person without the need for material
modification by the non-resident person), or
• the non-resident person has any other form of nexus in the United Arab Emirates
as might be specified through a Cabinet decision.
A fixed or permanent place in the United Arab Emirates will not be considered a PE if it
is used solely for conducting activities of a preparatory or auxiliary nature. The mere
presence of a natural person in the United Arab Emirates will not create a PE for a non-
resident person in the following instances:
• Such a presence is a consequence of a temporary and exceptional situation.

• The natural person is employed by the non-resident person and its activities in
the United Arab Emirates are not part of the core income-generating activities of
the non-resident person or its related parties.
The UAE CT Law further provides an investment manager exemption, which allows an
investment manager (i.e. a person who provides brokerage or investment management
services subject to regulatory oversight in the United Arab Emirates) to be considered
an independent agent when acting on behalf of a non-resident person for purposes of
determining whether the investment manager will create a PE in the United Arab
Emirates. This applies to investment managers who deal in transactions involving,
amongst others, commodities, real property, bonds, shares, derivatives, securities, or
foreign currency.
Corporate - Other taxes

Value-added tax (VAT)

VAT was introduced in the United Arab Emirates on 1 January 2018. The general VAT
rate is 5% and applies to most goods and services, with some goods and services subject
to a 0% rate or an exemption from VAT (subject to specific conditions being met).
The 0% VAT rate applies to goods and services exported outside the VAT-implementing
Gulf Cooperation Council (GCC) member states, international transportation, the supply
of crude oil/natural gas, the first supply of residential real estate, and some specific
areas, such as health care and education.
Further, according to Cabinet Decision (No. 46 of 2020) on 4 June 2020, a person shall
be considered as being ‘outside the state’, and thus fall under zero-rating export of
services if they only have a short-term presence in the state of less than a month and the
presence is not effectively connected with the supply.
A VAT exemption applies to certain financial services, as well as to the subsequent

supply of residential real estate. Further, transactions in bare land and domestic
passenger transport are also exempt from VAT.
Certain transactions in goods between companies established in UAE Designated (Free)

Zones (DZs) may not be subject to VAT. The supply of services within DZs is, however,
subject to VAT in accordance with the general application of the UAE VAT legislation.
For UAE resident businesses, the mandatory VAT registration threshold is AED
375,000 and the voluntary registration threshold is AED 187,500. No registration
threshold applies to non-resident businesses making supplies on which the UAE VAT is
required to be charged.
VAT grouping is allowed, provided certain conditions are met.
There are specific documentary and record-keeping requirements, such as the

requirement to issue tax invoices and submit VAT returns (on a quarterly or monthly
basis depending on the allocation by the FTA).
Excess input VAT can, in principle, be claimed back from the FTA, subject to a specific
procedure. Alternatively, VAT credits may be carried forward and deducted from future
output VAT.
Businesses that do not comply with their VAT obligations can be subject to fines and
penalties. There are both fixed and tax-geared penalties.
Customs duties
Generally, a customs duty of 5% is imposed on the cost, insurance, and freight (CIF)
value of imports. Other rates may apply to certain goods, such as alcohol and tobacco,
and certain exemptions and reliefs may also be available. Further, the United Arab
Emirates imposes anti-dumping duties on imports of certain goods, such as car
batteries, ceramic and porcelain tiles, and hydraulic cement. The anti-dumping duty
rates vary depending on the HS codes of the goods and country of export and/or origin.
In some cases, the anti-dumping duty is 67.5% of the CIF value of the goods.
The United Arab Emirates is part of the GCC Customs Union, which was established in
2003 to remove customs and trade barriers among the GCC member states. No customs
duties are levied on trade between the GCC member states (subject to certain
conditions). Additionally, the United Arab Emirates grants duty-free imports to most
national goods originating in member countries of the Greater Arab Free Trade
Agreement, Singapore, the European Free Trade Association countries (i.e. Norway,
Switzerland, Iceland, and Liechtenstein), Israel, and India.
While the UAE free trade zones (FTZs) are areas within the territory of the United Arab
Emirates, these are considered outside the scope of the customs territory. Therefore,
goods imported into the UAE FTZs are not subject to customs duty. Customs duty is
suspended until the goods are imported into the GCC local market.
Excise taxes
On 1 October 2017, the United Arab Emirates introduced an excise tax on tobacco and
tobacco products, carbonated drinks, and energy drinks.
On 1 December 2019, the United Arab Emirates expanded the scope of excise tax to
include sweetened drinks, electronic smoking devices, and tools, as well as liquids used
in electronic smoking devices and tools.
The applicable tax rates are as follows:
• 100% on tobacco and tobacco products, electronic smoking devices and tools,
liquids used in electronic smoking devices and tools, and energy drinks.
• 50% on carbonated drinks and sweetened drinks.
Municipal or property tax

Most Emirates impose a municipality tax on properties, mostly by reference to the
annual rental value. It is generally the tenants' obligation to pay the tax. In some cases,
separate fees are payable by both tenants and property owners. For example, in the
Emirate of Dubai, the municipality tax on property is currently imposed at 2.5% on
annual rental value for commercial properties (paid by property owners) and 5% for
residential properties (paid by tenants).
A registration fee may be levied on the transfer of ownership of land or real property.
For example, a land registration fee is levied in the Emirate of Dubai at a rate of 4% of
the fair market value of the property, payable to the Dubai Land Department. In Dubai,
the registration fee may also apply to the direct or indirect transfer of shares in an
entity that owns real property.
These levies are imposed and administered differently by each Emirate.
Stamp taxes
Currently, there are no separate stamp taxes levied in the United Arab Emirates.
Payroll taxes
Since there is currently no personal income tax in the United Arab Emirates, there is no
payroll tax withholding obligation for employers.
Social security contributions

There is a social security regime in the United Arab Emirates that applies to qualifying
UAE and other GCC national employees only. Non-GCC nationals are not subject to social
security in the United Arab Emirates.
For UAE national employees (with the exception of those employed in Abu Dhabi),
social security contributions are calculated at a rate of 20% of the employee's gross
remuneration as stated in the local employment contract. Social security obligations
also apply to employees of companies and branches registered in an FTZ. Out of the
20%, 5% is payable by the employee, 12.5% is payable by the employer, and an
additional 2.5% contribution is made by the government. A higher rate of 26% is
applied in the Emirate of Abu Dhabi, where the contribution of the employer is
increased to 15%, the government’s contribution is increased to 6%, and the employee’s
contribution remains at 5%. The contributions are subject to a statutory minimum and
maximum salary amount (against which the amount of the pension contributions is
calculated) of AED 1,000 and AED 50,000, respectively.
For other GCC nationals working in the United Arab Emirates, social security
contributions are determined in accordance with the social security regulations of their
home country.
The employer is responsible for withholding and remitting employee social security
contributions together with the employer’s share.
In the Dubai International Financial Centre (DIFC), the DIFC Employee Workplace
Savings Scheme (DEWS) has been introduced, replacing the End of Service Gratuity
Benefit (EOSG), with the aim of protecting long-term employee savings. The new
scheme was rolled out on 1 February 2020, and employers now are required to make
monthly contributions to DEWS or an alternative regulated Qualifying Scheme, as
opposed to paying a lump sum ‘gratuity payment’ to an employee at the end of their
employment. Employers are required to contribute monthly contributions of 5.83% or
8.33% of the employee’s basic salary (the actual percentage is contingent upon the
employee’s length of service) into the scheme.
Corporate - Branch income
In certain Emirates, branches of foreign banks are governed by special banking tax
decrees, under which they are taxed at 20% of their adjusted taxable income.
Under UAE CT Law, a branch of a non-resident person could be regarded as a PE in the

United Arab Emirates and the income attributable to such branch could be subject to
UAE CT.
The United Arab Emirates does not have a branch profits tax. Repatriation of profits
between branches and their head offices are also not subject to withholding tax (WHT)
or other forms of repatriation tax in the United Arab Emirates.
Corporate - Income determination

The tax decrees of the various Emirates provide that taxable income is calculated by
reference to the financial accounting profit, subject to certain book-tax adjustments.
Under the UAE CT Law, the accounting net profit (or loss) as stated in the standalone
financial statements of a business is taken as the starting point for determining its
taxable income. The law prescribes a number of key adjustments to the accounting net
profit (or loss) in order to compute the taxable income.
The following table sets out the aspects to consider when determining the nature of a
taxable person (i.e. resident vs. non-resident) as well as the applicable tax base:
Resident person Tax base
An entity that is incorporated in the United Arab

Worldwide income
Emirates (including a Free Zone entity)
A foreign entity that is effectively managed and

Worldwide income
controlled in the United Arab Emirates
A natural person/individual who conducts a

business or business activity in the United Arab Worldwide income
Emirates
Any other person (may be determined by a Cabinet

Worldwide income
decision)
Non-resident person Tax base

Resident person Tax base
Taxable income attributable

Has a PE in the United Arab Emirates
to the PE
The UAE-sourced income

Derives UAE-sourced income
not attributable to the PE
Taxable income attributable

Has nexus in the United Arab Emirates
to the nexus
Capital gains
There are no separate capital gains provisions under the UAE CT law. Any gains / (loss)
on the disposal of capital assets would form part of the taxable income, which would be
subject to a 0% or 9% tax rate as the case may be.
Unrealized gains or losses

Based on the CT Law and the FAQs, a taxable person who prepares financial statements
on an accrual basis of accounting can opt for the following:
• Elect to recognize gains and losses on a ‘realization basis for CT Law purposes (i.e. any
and all unrealized gains would not be taxable [and conversely, any and all unrealized
losses would not be deductible] until they are realized).
• Elect to recognize gains and losses on a ‘realization basis for CT Law purposes for assets
and liabilities held on capital account only (i.e. only unrealized gains and losses in
respect of assets and liabilities held on capital account would not be taxable or
deductible, respectively, until they are realized). Unrealized gains and losses arising from
assets and liabilities held on revenue account, on the other hand, would continue to be
included in taxable income on a current basis.
Exempt Income
To avoid instances of double taxation, and recognizing the United Arab Emirates’
position as an international business hub and leading holding company location, the
UAE CT regime exempts dividends and other profit distributions received by a taxable
person from a UAE tax resident entity (i.e. local dividends) or received from non-UAE
tax resident persons, as well as other types of income as detailed below.
Participation exemption
Dividends and other profit distributions relating to an ownership interest (referred to

as a ‘participating interest’) in a foreign juridical person (referred to as ‘participation’)
will be exempt from tax if:
• the ownership interest is at least 5%

• a 12-month uninterrupted holding period (or the intention to hold for 12 months) is in
place
• the participation is subject to tax in its country or territory of residence at a rate that is
not lower than 9%, and
• not more than 50% of the assets directly or indirectly owned by the participation consist
of an ownership interest or entitlements that would not qualify for the participation
exemption if these assets were held directly by the taxable person.
The ‘subject to tax’ test would be satisfied if:
• A 9% effective tax rate (ETR) is applied on the income or profits of the participation.
• In the event such a 9% ETR is not applicable based on the relevant jurisdiction’s tax
regime, a 9% ETR is reached if re-calculated based on the provisions of the UAE CT Law.
Further, an entity could be treated as satisfying the condition that it must be subject to
tax at a rate that is not lower than the UAE CT rate (i.e. at least 9%) if its principal
business objective and activity is to acquire and hold shares or equitable interests that
are considered as participating interests and the income of the participation during the
relevant tax period substantially consists of income from participating interests. The tax
rate requirement will also be treated as met where the juridical person is a QFZP or
exempt person.
A participating interest of less than 5% could also qualify for the exemption where the
acquisition cost of the ownership interest exceeds AED 4 million.
Foreign permanent establishment exemption
A resident person could create a PE in another jurisdiction based on the domestic tax
laws of this jurisdiction, subject to any tax treaty. Generally, the income attributed to
such a foreign PE will be taxed in that jurisdiction. In such a scenario, the UAE CT Law
provides an option to the resident person to elect for an exemption of this income in the
United Arab Emirates. The exemption will be available if the foreign PE is subject to CT
or similar taxes at a rate not less than 9% in the foreign jurisdiction. If the resident
person opts for this exemption, it will not be eligible to take into account losses, income,
expenditure, and foreign tax credits in relation to the foreign PE in the United Arab
Emirates.
International transportation exemption
Income earned by a non-resident from operating aircraft or ships in international

transportation will not be subject to CT in the United Arab Emirates if the income
earned by a UAE resident person who carries on these activities is exempt from CT in
the jurisdiction of the non-resident.
Partners in an unincorporated partnership

As a general rule, an unincorporated partnership will not be treated as a taxable person,
i.e. the partnership is looked through and each partner is treated as a taxable person on
their distributive share. This would mean each partner would be responsible for
complying with UAE CT administration and compliance burdens and for paying UAE CT
on their taxable income as if each carrying on independent business subject to UAE CT.
Assets, liabilities, income, and expenditures of the partnership should be allocated to
each partner in accordance with their distributive share.
Partners in an unincorporated partnership can make an irrevocable (save exceptional

circumstances) application to the FTA for the unincorporated partnership to be treated
as a taxable person, i.e. to be recognized as its own entity subject to UAE CT. Where this
application is made, partners remain jointly and severally liable for the partnership’s CT
liability. One partner will be appointed as the responsible partner for any UAE CT
obligations and proceedings for the partnership.
Foreign partnerships
Foreign partnerships will be treated as unincorporated partnerships where the
partnership is not subject to tax under the laws of the foreign jurisdiction and each
partner is individually subject to tax on their distributive share of the partnership’s
income when the partnership receives or accrues it. Partnerships are flexible vehicles
that are typically complex from a tax perspective. The approach adopted in the UAE CT
law attempts to simplify the tax treatment and is in line with international best practice.
Family foundations
The CT Law identifies family foundations, trusts, and similar entities as independent
juridical persons that are used to protect and manage the assets of an individual or a
family with a separate legal personality. A family foundation can apply to be treated as a
transparent ’unincorporated partnership ‘for UAE CT purposes under certain
conditions. This would generally prevent the income of the foundation or trust from
attracting UAE CT and could be a useful vehicle for families to ensure a tax efficient
holding structure, proper governance, as well as succession planning.
Corporate - Deductions
Expenditure that is not of a capital nature and is incurred wholly and exclusively for the
purposes of the taxable person’s business should generally be tax deductible. The UAE
CT Law disallows/restricts the deduction of certain expenses. This is to ensure that
relief can only be obtained for expenses incurred for the purpose of generating taxable
income and to address possible situations of abuse or excessive deductions.
Where expenditure is incurred for more than one purpose, a deduction will be allowed
for any identifiable part or proportion of the expenses incurred wholly and exclusively
for deriving taxable income. Also, an appropriate proportion of any unidentifiable part
or proportion of the expenses incurred for the purposes of deriving taxable income that
has been determined on a fair and reasonable basis can be claimed for deduction for
UAE CT purposes.
Depreciation and amortization

The CT Law is silent on the tax treatment of depreciation/amortization.
Interest expenses
The UAE CT Law provides that net interest expense (NIE) up to 30% of tax adjusted
earnings before interest taxes depreciation and amortisation (EBITDA) will be
deductible. However, this should not apply if the NIE for the relevant tax period does
not exceed the threshold of AED 12 million. If this threshold is exceeded, the taxable
person may deduct the higher of the threshold or 30% of EBITDA.
The following would be considered as interest for the purpose of the general interest
limitation rule:
• Amounts incurred in connection with raising finance (including guarantee fees,

arrangement fees, commitment fees, and any other fees similar in nature).
• Interest on Islamic Financial Instruments that is compliant with the Sharia
principles or any equivalent instruments or the combination of both,
• Interest component on forward contracts, futures contracts, options, interest
rate and foreign exchange swap agreements, or any other financial derivative
instruments.
• The finance element of finance and non-finance lease payments.
• Foreign exchange gains.
EBITDA is mainly the taxable income adjusted for the following items:
• NIE for the relevant tax period (excluding any in relation to qualifying
infrastructure projects).
• Depreciation and amortisation expenditure taken into account in determining
the taxable income for the relevant tax period.
• Any interest income or expenditure relating to historical financial assets or
liabilities held prior to 9 December 2022.
If the EBITDA arrived at after the above calculation is negative, the amount of EBITDA to
be considered for determining the 30% limit will be AED 0.
The NIE attributed to debt instruments, the terms of which are agreed prior to 9
December 2022, are exempt from the application of the general interest limitation rule.
NIE incurred by a qualifying infrastructure project person will not be subject to the
general interest limitation rule.
Interest capping rules will not apply to banks, insurance businesses, and certain other
regulated financial service entities. Also, interest capping rules will not apply to
businesses carried on by natural persons/individuals or any other person that may be
determined by a Cabinet decision.
The net interest expense amount disallowed for deduction under the interest capping
rules could be carried forward and deducted in the subsequent ten tax periods.
In addition to the general interest limitation rule set out above, no interest deduction
will be allowed if the loan was obtained, directly or indirectly, from a related party for
the following transaction with the related party:
• dividends/profit distribution
• redemption, repurchase, reduction, or return of share capital
• capital contribution, or
• acquisition of ownership interest in a legal entity, who is or becomes a related
party following acquisition.
Charitable contributions
Donations paid to entities that are non-qualifying public benefit entities will not be
considered as deductible for UAE CT purposes.
Entertainment expenses
Expenses associated with entertainment of customers, shareholders, suppliers, and
other business partners, such as meals, accommodation, transportation, admission fees,
facilities, and equipment used for entertainment and other expenses specified by a
Cabinet decision, can be deducted up to 50% of the amount incurred.
Bribes, kickbacks, and illegal payments

Bribes or other illicit payments will not be considered as deductible for UAE CT
purposes.
Fine and penalties

Fines and penalties (other than compensation for damages for breach of the contract)
will not be considered as deductible for UAE CT purposes.
Taxes
CT, recoverable VAT, and taxes imposed outside the United Arab Emirates will not be
considered as deductible for UAE CT purposes.
Other non-deductible expenses

Dividends/profit distribution and other expenses specified in the Cabinet decision will
not be considered as deductible for UAE CT purposes.
Net operating losses

The CT Law provides that a business can offset tax losses against the taxable income of
subsequent tax periods when computing the taxable income for that period. The set-off
during any tax period cannot exceed 75% of the taxable income for the tax period
(except in circumstances that may be prescribed in a Cabinet decision). Any tax loss
remainder can be carried forward to a further subsequent tax period indefinitely.
A taxable person cannot claim tax loss relief for losses incurred before the date of
commencement of the UAE CT regime, losses incurred before it became a taxable
person under the CT Law, and losses incurred from an asset or activity the income of
which is exempt or otherwise not taken into account under the CT Law.
UAE CT allows the transfer of tax losses between group entities where there is 75% or
more common ownership and where other certain conditions are met, such as having
the same financial year and using the same accounting standards and not being an
exempt person or QFZP.
To curb the transfer of tax losses through the transfer of ownership in case of taxable
persons that are not listed on a recognized stock exchange, the CT Law provides that the
tax losses can only be carried forward and utilized by a taxable person on the
satisfaction of the following conditions:
• The same person or persons continuously owned at least a 50% ownership

interest in the taxable person from the beginning of the tax period in which the
tax loss is incurred to the end of the tax period in which the tax loss or part
thereof is offset against the taxable income of that period.
• The taxable person continued to conduct the same or a similar business
following a change in ownership of more than 50%.
Corporate - Group taxation

UAE group entities may elect to form a tax group provided all the following conditions
are met:
• The parent company, which must be a UAE tax resident, directly or indirectly holds at
least 95% of the (i) share capital, (ii) voting rights, and (iii) entitlement to profits and
net assets.
• They have the same financial year and prepare the financial statements using the same
accounting standards.
• Neither the parent company nor the subsidiary is an exempt person or a QFZP.
When a tax group is formed, the parent entity will be responsible for the administration,
such as the submission of one tax return and settlement of the tax liability for the tax
group.
Transfer pricing
The CT Law introduces transfer pricing rules and regulations. The transfer pricing
regulations take immediate effect coinciding with the effective date of the other tax
provisions.
Arm’s-length principle
Both cross-border and domestic transactions and arrangements between related

parties (including transactions undertaken by Free Zone entities) need to adhere to the
arm’s-length standard (i.e. transactions must be undertaken as if they are carried out
between independent parties under similar circumstances).
Furthermore, payments and benefits provided to connected persons should be at

market value, which should be determined by applying the arm’s-length standard.
Transfer pricing methods and their application
To determine the arm’s-length nature of the transactions between related parties, the
CT Law prescribes five methods, broadly aligned with the OECD Transfer Pricing
Guidelines. In case the taxable person can demonstrate that none of the prescribed
methods can be reasonably applied, the taxpayer is allowed to apply any other method.
In alignment with the OECD Transfer Pricing Guidelines, appropriate factors must be
considered when applying the most appropriate method, namely (i) contractual terms,
(ii) characteristics of the transaction, (iii) economic circumstances, (iv) functions,
assets, and risks, and (v) business strategies.
Related parties
The definition of related parties is broadly aligned with the previously issued public
consultation document and is summarised below:
• Two or more natural persons related up to the fourth degree of kinship.

• A natural person and a juridical person related by ownership (50% or greater) or
control.
• Two or more juridical persons related by ownership (50% or greater) or control.
• A person and its PE or foreign PE.
• Partners in the same unincorporated partnership.
• Trustee, founder, settlor, or beneficiary of a trust or foundation and its related parties.
In this regard, the term ‘control’ has now been defined as the ability of a person to
influence another person, including the ability to:
• exercise 50% or more voting rights

• determine the composition of 50% or more of the Board of Directors
• receive 50% or more profits, or
• exercise significant influence over the conduct/affairs of another person.
The CT Law does not provide clarification on how ’significant influence‘ is interpreted,
and it is yet to be seen whether additional guidance will be issued and whether or not
reference will be made to the interpretation as per accounting standards.
Connected persons
Any payment or benefit provided by a taxable person to a connected person should (i)
correspond to the market value of the service or benefit and (ii) be incurred wholly and
exclusively for business purposes in order for a deduction to be allowed. The market
value should be determined by applying the arm’s-length standard. A specific exclusion
on this limitation of deductibility applies in the event that the payment or benefit is
provided by:
• a taxable person whose shares are traded on a recognized stock exchange

• a taxable person subject to regulatory oversight of a competent state authority, and
• any other person to be determined under a separate decision, which is yet to be issued.
The definition of ’connected persons‘ is broadly aligned with the previously issued
public consultation document and could be any of the below:
• A natural person who directly or indirectly owns an ownership interest or controls the
taxable person.
• A director or officer of the taxable person.
• Partners in the same unincorporated partnership.
• Related party(ies) of any of the above.
Transfer pricing adjustments
The taxable income may be adjusted by the FTA if the results of the transaction between
related parties do not fall within the arm’s-length range.
In the event of an adjustment made by the FTA or a taxable person to the taxable
income, the authority will make a corresponding adjustment to the taxable income of
the related party that is party to the transaction. On the other hand, where an
adjustment is made by a foreign competent authority, the taxable person can apply for
corresponding adjustment relief. Further guidance is awaited on the exact mechanism
of implementation (e.g. potentially through a Mutual Agreement Procedure or other
mechanism).
Advance Pricing Agreement (APA)
The CT Law provides a person the option to make an application for an APA (existing or
proposed transactions). Detailed guidance in this regard will be prescribed by the FTA
at a later date.
Transfer pricing documentation
Taxpayers are required to maintain transfer pricing documentation, specifically a

Master File and a Local File, in case:
• the taxable person is part of a multinational enterprise (MNE) group with a total
consolidated group revenue of at least AED 3.15 billion in the relevant tax period, or
• the taxable person has revenues of at least AED 200 million or more in a relevant tax
period.
Furthermore, the following transfer pricing documentation requirements could be
applicable for taxable persons (in both the mainland and Free Zone):
• The FTA may require a taxable person to file a disclosure form along with the tax return,
containing information regarding the transactions and arrangements with related
parties and connected persons.
• The FTA may also require any taxable person to submit (within 30 days) any information
supporting the arm’s-length nature of the transactions and arrangements with related
parties and connected persons.
Corporate - Tax credits and incentives

Foreign tax credit

A credit is available for foreign taxes paid on a UAE-taxable person’s income. The
foreign tax credit is limited to the amount of CT due on the relevant income. Any
unutilized foreign tax credit cannot be carried forward or back and will ultimately be
lost.
Small business relief

The UAE CT Law provides tax relief for small businesses. A tax resident person may
elect to be treated as not having derived any taxable income where the revenue for the
relevant and previous tax periods does not exceed AED 3 million during each relevant
tax year. If such threshold is exceeded, then the taxable person will be subject to UAE CT
at the relevant rates as provided under the CT Law. The abovementioned revenue
threshold will be applicable starting on or after 1 June 2023. However, it will only apply
to subsequent tax periods that end before or on 31 December 2026. If a tax resident
person applies for ’small business relief‘, certain provisions of the CT Law will not apply,
such as exempt income, reliefs, deductions, tax loss relief, and transfer pricing
compliance requirements, as specified in the relevant chapters of the CT Law. The FTA
may request any relevant records or supporting information to verify the compliance
within a timeline (to be confirmed). If a taxable person intentionally separates its
business solely to meet the threshold of AED 3 million and elects not to be subject to
UAE CT, the FTA can make compensating adjustments to the UAE CT liability of the
relevant taxable person.
Transfers within a qualifying group

The UAE CT Law provides tax relief on intra-group transfer of assets or liabilities
between taxable persons that are members of the same qualifying group. Taxable
persons will be treated as members of the same qualifying group if all the following
conditions are met:
• The taxable persons are tax resident entities, or non-residents that have a PE in the
United Arab Emirates.
• The taxable persons are at least 75% commonly owned and have the same financial year
and prepare the financial statements using the same accounting standards.
• None of the taxable persons are regarded as an exempt person or a QFZP.
There is a clawback period of two years from the date of the initial transfer in the case
there is a subsequent transfer of such asset or liability outside the permitted group or
where the transferor or transferee ceases to be a member of the permitted group.
Business restructuring relief

Similar to the intra-group transfer of assets or liabilities within a qualifying group, the
UAE CT Law provides tax relief on mergers, spin-offs, and other corporate restructuring
transactions where the whole or an independent part of the business is being
transferred in exchange for shares or other ownership interest, provided the following
conditions are met:
• The transfer is undertaken in accordance with the applicable regulations in the United
Arab Emirates.
• The taxable persons are resident persons, or non-resident persons that have a PE in the
• None of the persons are regarded as an exempt person or a QFZP.
• They have the same financial year and prepare the financial statements using the same
accounting standards.
• The transfer is undertaken for valid commercial or economic reasons.
There is a clawback period of two years from the date of the transfer if there is a
subsequent transfer to a third party, or shares or ownership interests received are
transferred or otherwise disposed of, and the gains or losses on the initial transfer will
be reported in the period in which the subsequent transfer is made to the third-party.
Free trade zones (FTZs)

Companies and branches registered in a Free Zone are considered taxable persons
under the UAE CT Law and are required to meet normal compliance obligations,
including transfer pricing requirements. However, provided a Free Zone entity meets
the conditions to be considered a Qualifying Free Zone Person (QFZP), it should be
eligible for a 0% UAE CT rate on its qualifying income. The income of a QFZP that is not
qualifying income will be taxed at a 9% CT rate.
In order to qualify for the 0% UAE CT rate, a QFZP must meet all of the following
conditions:
• Be a Free Zone person (i.e. a juridical person incorporated, established, or otherwise

registered in a Free Zone, including branches).
• Maintain adequate substance in the United Arab Emirates (in a Free Zone).
• Derive qualifying income.
• Not have made an election to be subject to the standard UAE CT regime.
• Comply with all transfer pricing rules and documentation requirements.
• Its non-qualifying revenue does not exceed the de minimis requirements.
• Prepares audited financial statements.
• Meet any other conditions as prescribed by the MoF.
Adequate substance
In order to maintain adequate substance in a Free Zone, the QFZP’s core income-
generating activities (CIGAs) shall be undertaken in a Free Zone and the QFZP must
maintain adequate assets, an adequate number of qualified employees, and incur an
adequate amount of operating expenditures.
The QFZP may opt to outsource its CIGAs to a related party in a Free Zone or a third
party in a Free Zone, and the QFZP must have adequate supervision of the outsourced
activity.
Qualifying income
Qualifying income includes the following:
• Income derived from transactions with other Free Zone persons, except for income
derived from ‘excluded activities’.
• Income derived from transactions with a non-Free Zone person, but only in respect of
‘qualifying activities’ that are not ‘excluded activities’.
• Any other income, provided that the QFZP satisfies the de minimis requirements.
Excluded activities
Excluded activities include the following:
• Transactions with natural persons (subject to certain exceptions under ‘qualifying

activities’ related to shipping and aircraft plus fund, wealth, and investment
management).
• Regulated banking, finance, leasing, and insurance activities.
• Ownership or exploitation of intellectual property assets.
• Ownership or exploitation of immovable property, except for transactions with Free
Zone persons in relation to commercial property located in a Free Zone.
Qualifying activities
Qualifying activities include the following:
• Manufacturing or processing of goods or materials.

• Holding of shares and other securities.
• Ownership, management, and operation of ships.
• Regulated reinsurance, fund management, wealth, and investment management.
• Headquarters, treasury, and financing services to related parties.
• Financing and leasing of aircraft.
• Logistics.
• Distribution of goods or materials in or from a Designated Zone to a customer that
resells such goods or materials, or parts thereof, or processes or alters such goods or
materials, or parts thereof, for the purposes of sale or resale.
• Any activities that are ancillary to the activities listed above (i.e. serve no independent
function but are necessary for the performance of the main qualifying activity).
The activity of distributing goods or materials must be undertaken in or from a
Designated Zone, and the goods or materials entering the state must be imported
through the Designated Zone.
Generally, the listed excluded and qualifying activities shall have the meaning provided
under the respective laws regulating these activities, unless otherwise prescribed.
De minimis requirements
The de minimis requirements will be satisfied where non-qualifying revenue does not
exceed 5% of total revenue or AED 5 million, whichever is lower. Non-qualifying
revenue is revenue derived from excluded activities or activities that are not qualifying
activities where the other party is a non-Free Zone person.
Certain revenue shall not be included in the calculation of non-qualifying revenue and
total revenue. This includes revenue attributable to certain immovable property located
in a Free Zone (non-commercial property, and commercial property where transactions
are with non-Free Zone persons). It also includes revenue attributable to a domestic PE
or a foreign PE.
Where a Free Zone person fails to meet any of the qualifying conditions set out in UAE
CT Law and in the corresponding Decisions, it will be treated as a taxable person subject
to a 9% CT rate for a minimum of five tax years.
Domestic PE
The Decisions introduce the concept of a domestic PE where a QFZP has a place of
business or other form of presence outside the Free Zone in the United Arab Emirates.
Income attributable to a domestic PE should be calculated as if the establishment was a
separate and independent person and shall be subject to CT at 9%. However, it will not
disqualify the Free Zone person from benefitting from a 0% CT rate on qualifying
income or be factored into the de minimis test (as above). A mainland branch of a QFZP
will therefore generally constitute a domestic PE and be subject to CT at 9%.
Corporate - Withholding taxes

With the broader objective of having a simplified yet robust UAE CT regime to reduce
the compliance burden for taxpayers, a WHT (currently set at 0%) will apply to certain
types of UAE-sourced income derived by non-residents insofar as it is not attributable
to a PE of the non-resident. The applicable WHT rate, as well as the categories of income
to which WHT applies, may be set out in a decision issued by the Cabinet.
Given the current 0% WHT rate, it is not expected that there will be any registration or
filing obligation.
WHT credits
A credit is available for WHT suffered by a taxable person to reduce the CT payable. This
WHT credit is limited to the lower of the amount of WHT deducted by the taxable
person under the UAE CT Law and the CT due under this law.
Any excess of the WHT credit will be refunded to the taxable person.
Tax treaty network
UAE national or resident individuals and UAE resident companies have access to an
extensive and growing double tax treaty (DTT) network. The DTTs could allow for relief
from taxation in DTT partner countries. The DTTs currently in force are listed below. A
number of other DTTs are at various stages of negotiation and ratification.
WHT (%)
Recipient
Dividends Interest Royalties
Albania 0/5/10 0 5
Algeria 0 0 10
Andorra 0 0 0
Angola 8 8 8
Argentina 10/15 12 10
Armenia 0/3 0 5
Austria 0/10 0 0
Azerbaijan 5/10 0/7 5/10
Bangladesh 5/10 10 10
Barbados 0 0 0
Belarus 5/10 0/5 5/10

WHT (%)
Recipient
Belgium 0/5/10 0/5 0/5
Belize 0 0 0
Bermuda 0 0 0
Bosnia and
0/5/10 0 0/5
Herzegovina
Botswana 5/7.5 7.5 7.5
Brazil 5/15 0/10/15 15
Brunei 0 0 5
Bulgaria 0/5 0/2 0/5
Cameroon 0/10 0/7 10
Canada 5/10/15 0/10 0/10
China, People’s
0/7 0/7 10
Republic of
Comoro Islands 0 0 0
Costa Rica 0/5/15 0/5/10 12
Croatia 5 5 5
Cyprus 0 0 0
WHT (%)
Recipient
Czech Republic 0/5 (1) 0 (1) 10 (1)
Egypt 5/10 0/10 10
Estonia 0 0 0
Ethiopia 5 5 0/5
Fiji 0 0 10
Finland 0 0 0
France 0 0 0
Georgia 0 0 0
Greece 0/5 0/5 10
Guinea 0 0 0
Hong Kong 0/5 0/5 5
Hungary 0 0 0
India 10 0/5/12.5 10
Indonesia 0/10 0/5 5

WHT (%)
Recipient
Ireland 0 0 0
Israel 0/5/15 0/5/10 12
Italy 5/15 0 10
Japan 5/10 0/10 10
Jersey 0 0 0
Jordan 7 0/7 10
Kazakhstan 0/5 0/10 10
Kenya 5 10 10
Korea, Republic of 5/10 0/10 0
Kosovo 0/5 0/5 0
Kyrgyzstan 0 0 5
Latvia 0/5 0/2.5 5
Lebanon 0 0 5
Liechtenstein 0 0 0
WHT (%)
Recipient
Lithuania 0/5 0 5
Luxembourg 0/5/10 0 0
Malaysia 0/10 (2) 0/5 10
Maldives 0 0 0
Malta 0 0 0
Mauritania 0 0 0
Mauritius 0 0 0
Mexico 0 0/4.9/10 10 (1)
Moldova 5 6 6
Montenegro 0/5/10 0/10 0/5/10
Morocco 0/5/10 0/10 0/10
Mozambique 0 0 0/5
Netherlands 0/5/10 0 0
New Zealand 15 0/10 10

WHT (%)
Recipient
Niger 0 0 10
North Macedonia 0/5 0/5 0/5
Pakistan 10/15 0/10 12
Panama 5 0/5 5
Paraguay 15 6/15 15
Philippines 0/10/15 0/10 10
Poland 0/5 0/5 5
Portugal 5/15 0/10 5
Romania 0/3 0/3 3
Russia (3) 0 0 N/A
San Marino 0 0 10
Saudi Arabia 5 0 10
Senegal 5 5 5
Serbia 0/5/10 0/10 10
Seychelles 0 0 5
WHT (%)
Recipient
Singapore 0 (1) 0 (1) 0/5 (1)
Slovakia 0 0/10 0/10
Slovenia 0/5 0/5 5
South Africa 5/10 10 10
Spain 0/5/15 0 0
Sri Lanka 0/10 0/10 10
St. Vincent & the

0 0 0
Grenadines
Sudan 0 0 0/5
Switzerland 0/5/15 0 0
Syria 0 0/10 18
Tajikistan 0 0 10
Thailand 10 (1) 0/10/15 (1) 15
Tunisia 0 2.5/5/10 7.5
Turkey 5/10/12 0/10 10

WHT (%)
Recipient
Turkmenistan 8 8 10
Ukraine 0/5 (1) 0/3 (1) 0/10 (1)
United Kingdom 0/15 0/20 0
Uruguay 5/7 (1) 0/10 0/5/10
Uzbekistan 0/5/15 0/10 10
Venezuela 0/5/10 0/10 10
Vietnam 0/5/15 0/10 10
Yemen 0 0 10
Zimbabwe 5 0 9
Notes
1. This DTT includes a ‘favoured nation’ clause. If this jurisdiction ever concludes a
more favourable treaty WHT rate with a country other than the United Arab
Emirates, then the more favourable treaty WHT rate will automatically apply to
the UAE treaty as well. Note that the above-mentioned rates do not reflect the
more favourable DTT rates but only the rates presented in the DTT between the
United Arab Emirates and the relevant jurisdiction. The more favourable rates
will need to be confirmed separately.
2. The UAE-Malaysia DTT provides for a reduced rate of 10% where dividend
payments are made from a UAE entity to a Malaysian entity. The DTT, however,
provides for a lower rate of 0% where payments are made from a Malaysian
entity to a UAE entity.
3. Government institutions only.
Corporate - Tax administration
The FTA will be responsible for the administration, collection, and enforcement of UAE
CT, while the MoF will remain the ‘competent authority’ in terms of international tax
agreements and the exchange of information for tax purposes.
Taxable period
A taxable person’s tax period is the financial year (the Gregorian calendar year or the
12-month period for which financial statements are prepared) or part thereof for which
a UAE CT return is required to be filed.
A taxable person can make an application to the FTA to change the start and end date of
its tax period, or use a different tax period, subject to the following conditions:
• The change is for liquidation purposes.

• The change is for aligning the taxable person’s financial year either for tax grouping,
financial reporting, or domestic and foreign tax relief purposes.
• There is a valid commercial, economic, or legal reason to change the tax period.
• The UAE resident person has not yet filed the tax return with the FTA for which they are
requesting a change in the tax period.
• The application is made no later than six months after the end of the original tax period
(i.e. three months before the original tax return is due).
It is important to note that a taxable UAE resident person may only change the relevant
tax period by means of either extending the current tax period to be a maximum of 18
months or shortening the following tax period to be a minimum of 6 months and a
maximum 12 months.
CT registration, returns, and payments

Every taxable person will be required to electronically register for UAE CT with the FTA
within a prescribed timeline and obtain a Tax Registration Number. The registration
will need to be undertaken even if the taxable person has already been registered for
VAT purposes.
In order to keep the administrative burden on taxpayers to a minimum, the CT Law

requires a taxable person to file only one tax return for each tax period.
The filing will need to be done electronically no later than nine months from the end of
the relevant tax period. Any UAE CT payable will also need to be settled within these
timelines.
Please see examples in the table below:
Due date of filing Due date for first

Fiscal year- First reporting Registration
first CT return and transfer pricing
end period date
payment disclosure form
January 2024
December To be 30 September
to December 30 September 2025
2023 determined 2025
2024
July 2023 to To be
June 2023 31 March 2025 31 March 2025
June 2024 determined
Tax assessment
A taxable person may be subject to a UAE CT assessment in accordance with the Tax
Procedures Law. In case a non-compliance to the CT Law is identified during the
assessment, penalties, and fines determined per the Tax Procedures Law could be
imposed.
Financial statements
A taxable person may be required to submit the financial statements used to determine
the taxable income for a tax period in the form and manner and within the timeline
prescribed by the FTA.
Taxable persons shall prepare financial statements by applying International Financial

Reporting Standards (IFRS). Such financial statements shall be audited if the taxable
person earns revenue exceeding the threshold of AED 50 million during a relevant tax
period or if the taxable person is regarded as a QFZP.
In case the revenue does not exceed AED 3 million or through an application in
exceptional circumstances to the FTA, the financial statements may be prepared on a
cash basis (as opposed to accrual).
Record keeping
A taxable person must maintain all relevant records and documents for the following
periods:
• The retention period for real estate records is seven years from the end of the calendar
year in which such record or document was created.
• The general document retention period of five years will be extended by one year
starting from the date of submission of voluntary disclosure in the fifth year from the
end of the relevant tax period.
• Additional four years in case of ongoing tax audit, tax dispute, or a notification by FTA on
a pending tax audit.
• Legal representatives are required to continue to retain the required books and records
of the person they were representing for a period of one year from the date on which
such legal representation ends.
Clarifications
A person can make an application to the FTA for clarification regarding any part of the
UAE CT Law or for concluding an APA for a transaction or arrangement.
General anti-abuse rule (GAAR)

In line with international best practice, the UAE CT Law includes a GAAR, which applies
to transactions giving rise to a tax advantage where no valid commercial reason exists
and where the tax advantage was the main or one of the main purposes of the
transaction.
Where the GAAR applies, the FTA can make a determination that one or more specified
CT advantages are to be counteracted or adjusted. If such a determination is made, the
FTA must issue an assessment giving effect to the determination and can make
compensating adjustments to the UAE CT liability of any other person affected by the
determination.
In any proceeding concerning the application of the GAAR, the FTA must demonstrate
that the determination made is just and reasonable.
Corporate - Other issues

Base erosion and profit shifting (BEPS)

The United Arab Emirates joined the G20 / OECD Inclusive Framework on BEPS (the
'Inclusive Framework') on 16 May 2018. Through joining the Inclusive Framework, the
United Arab Emirates has committed to implement, in the immediate to short term, the
following four BEPS minimum standards Actions:
• Action 5: Countering harmful tax practices.

• Action 6: Countering tax treaty abuse.
• Action 13: Transfer pricing documentation and CbC reporting.
• Action 14: Improving dispute resolution mechanisms.
The United Arab Emirates has also committed to implementing the other (11) BEPS
measures in the medium to long term.
On 30 April 2019 and amended in 2020, the United Arab Emirates issued its CbC
reporting regulations, which are in line with the guidance issued by the OECD on CbC
reporting. The rules introduce a CbC reporting requirement (either filing or
notification) for ultimate parent entities that are tax resident in the United Arab
Emirates and that are part of a multinational group with consolidated revenues equal to
or exceeding AED 3.15 billion in the preceding financial year. CbC reporting
requirements are applicable to ‘financial reporting years’ starting on or after 1 January
2019 with the relevant CbC report to be submitted within 12 months from the end of
the reporting year.
Failure to comply with the CbC reporting requirements is likely to expose the UAE
taxpayers concerned to stringent and varying levels of administrative penalties in the
The United Arab Emirates has signed and ratified the BEPS Multilateral Instrument
(MLI). The key positions that the United Arab Emirates decided to adopt include:
• The United Arab Emirates has chosen to include additional wording in the preamble of
its Double Tax Treaties (DTT)s stating that the DTTs should not be used for treaty abuse
(BEPS Action 6 minimum standard).
• The United Arab Emirates has chosen to include a principal purpose test with the ability
to refer to a competent authority for the final assessment of the availability of treaty
benefits (BEPS Action 6 minimum standard).
• The United Arab Emirates has chosen to include additional wording in its DTTs to
improve the dispute resolution process through Mutual Agreement Procedures (BEPS
Action 14 minimum standard).
• The United Arab Emirates has chosen to retain the existing 'permanent establishment'
definition in its DTTs and has not elected to adopt the expanded 'permanent
establishment' definition.
• The United Arab Emirates has chosen to retain its existing position on the taxation of
capital gains realized on real estate-rich entities and has not elected to adopt the
proposed 'real estate rich' provisions in its existing DTTs.
In respect to the remaining measures included under the United Arab Emirates' MLI
position, the United Arab Emirates has opted to agree with specific changes to its DTTs
through bilateral negotiation.
Economic substance regulations

In scope entities
On 30 April 2019, the UAE MoF issued economic substance regulations (Regulations),
which were followed by the amended Regulations on 1 September 2020 introducing a
requirement for certain juridical persons (persons with separate legal personalities)
and unincorporated partnerships that carry on a 'relevant activity' in the United Arab
Emirates (UAE Licensees) to have adequate 'economic presence' in the United Arab
Emirates, relative to the activities they undertake.
Save for some limited exceptions, the Regulations apply to all UAE Licensees that
undertake one or more of the 'relevant activities' listed below:
• Banking.
• Insurance.
• Investment fund management.
• Lease-finance.
• Headquarters.
• Shipping.
• Holding company.
• Intellectual property (IP).
• Distribution and service centre.
The Regulations apply to financial periods commencing on, or after, 1 January 2019.
Only UAE Licensees that undertake and earn income from a 'relevant activity' are
required to satisfy the applicable economic substance test. The Regulations do not apply
to non-UAE tax-resident entities, investment funds, and their underlying SPVs /
investment holding entities (except for self-managed investment funds), wholly UAE
resident-owned UAE entities with domestic transactions only (that are not part of a
multinational group), and UAE branches of foreign companies that are subject to tax on
all their 'relevant income' in a foreign jurisdiction.
Compliance requirements
There are two filing requirements, being:
• Notification.
• Substance report (applicable only to entities that perform 'relevant activities' and
generate 'relevant income' from those 'relevant activities').
The notification and substance report should be submitted electronically via the MoF
online portal within 6 and 12 months of the financial year end of the UAE Licensee,
respectively. These filings must be made on an annual basis, if applicable.
Notification requirements
Under the Regulations, only entities that perform a 'relevant activity' should file a
notification. This filing should be made via the MoF online portal and will be due six
months after the entity’s financial year end (e.g. an entity with a 31 December financial
year end should file its notification by 30 June of the following year).
Annual return/declaration requirements
To satisfy the economic substance requirements, and unless the UAE Licensee is
carrying on a 'holding company business', the UAE Licensee must provide
documentation to support that, in the relevant financial period:
• the UAE Licensee’s relevant 'core income-generating activities' were conducted in the
United Arab Emirates
• the UAE Licensee was 'directed and managed' in the United Arab Emirates, and
• with reference to the level of activities performed in the United Arab Emirates:
•
o there was an adequate number of qualified full-time employees in the United
Arab Emirates
o an adequate amount of operating expenditure was incurred in the United Arab
Emirates, and
o there were adequate physical assets in the United Arab Emirates.
It is possible for a UAE Licensee to carry out more than one 'relevant activity' at a time,
in which case the economic substance requirements outlined above will need to be
satisfied for each 'relevant activity'.
A UAE Licensee undertaking a holding company business 'relevant activity' is subject to
reduced economic substance requirements. On the other hand, additional economic
substance documentary requirements apply to 'high-risk' IP-related activities.
In the event 'relevant income' (i.e. gross income relating to a 'relevant activity') is
generated, the UAE Licensee would be required to file an annual substance report via
the MoF’s Portal within 12 months of its financial year-end (e.g. by 31 December 2021 if
the UAE Licensee has a 31 December 2020 financial year-end).
Templates, supporting documentation, and the mechanism for the annual substance
report filing have been released by the MoF on their dedicated economic substance
landing page. In general, the following information is required to be submitted by the
UAE Licensee in the annual substance report:
• The 'relevant activity' conducted by the UAE Licensee.

• The amount of 'relevant income' in respect of the 'relevant activity'.
• The amount of operating expenses and tangible assets in respect of the 'relevant
activity'.
• The number of qualified full-time employees who are responsible for carrying on the
UAE Licensee’s 'relevant activity'.
• Confirmation of the 'core income-generating activity' performed in respect of the
'relevant activity'.
• The UAE Licensee’s financial statements.
• Declaration as to whether or not the UAE Licensee satisfies the economic substance test.
• In the case of a 'relevant activity' being an IP business, a declaration as to whether or not
it is a 'high risk IP business'.
If the UAE Licensee declares that it is a ‘high risk IP business’, the National Assessing
Authority (i.e. the Federal Tax Authority) will automatically determine that the UAE
Licensee did not meet the economic substance test unless the UAE Licensee can prove
otherwise. On this basis, the UAE Licensee should provide the National Assessing
Authority with information and documentation that it does and historically has
exercised a high degree of control over the development, exploitation, maintenance,
protection, and enhancement of the IP asset exercised by an adequate number of full-
time employees, with the necessary qualifications, who permanently reside and
perform their activities in the United Arab Emirates. This can be demonstrated through
submitting the following documents:
• Business plan showing the reasons for holding the ownership in the IP asset in the
• Employees' information, including level of experience, type of contracts, qualifications,
and duration of employment with the UAE Licensee.
• Evidence that decisions regarding the IP were made within the United Arab Emirates.
Where a 'core income-generating activity' of the UAE Licensee’s 'relevant activity' is

outsourced:
• the UAE Licensee must be able to monitor, control, and demonstrate adequate
supervision in the UAE of the 'core income-generating activity' being carried out by the
outsourcing provider
• the employees, expenditures, and physical assets of the outsourcing provider must be
adequate relative to the 'core income-generating activity' being carried out by them
• the 'relevant activity' being outsourced is a 'core income-generating activity' being
carried out in the United Arab Emirates, and
• the employees, expenditure, and physical assets of the outsourcing provider must not be
counted multiple times by multiple UAE Licensees when evidencing compliance with the
economic substance test.
It is anticipated that documentation supporting the above aspects will likely be

maintained to assist in the evaluation of whether a UAE Licensee has sufficient
economic substance in the United Arab Emirates relative to the activities it undertakes.
Consequences of non-compliance
In addition to exchanging information with foreign authorities and the ultimate parent
and beneficial owners of the UAE Licensee, failure to demonstrate adequate substance
would result in administrative penalties (AED 50,000 in the first year of failure,
increased to an amount of AED 400,000 for a consecutive year of failure). Additional
penalties, such as suspending, revoking, or not renewing the UAE Licensee’s trade or
commercial licence, could also apply.
Other administrative penalties include: (i) AED 20,000 for failure to submit the
notification; (ii) AED 50,000 for failure to submit the annual substance report, as well as
deemed failure to meet the economic substance test; and (iii) AED 50,000 for providing
inaccurate information, as well as deemed failure of the economic substance test.
United States (US) Foreign Account Tax Compliance Act

(FATCA)
On 17 June 2015, the United Arab Emirates signed the Model 1B Intergovernmental
Agreement (IGA) with the United States, which came into force on 19 February 2016
(US-UAE Model 1 IGA), with the US Internal Revenue Services (IRS) regarding the
exchange of information related to US individuals and certain type of US-owned entities,
with an effective date of 1 July 2014.
On 6 July 2015, the UAE MoF issued guidance notes on the requirements of the US-UAE
Model 1 IGA on the implementation of FATCA (UAE FATCA Guidance Notes). The UAE
FATCA Guidance Notes expand upon the UAE-US Model 1 IGA, including the definitions,
implementation of the due diligence procedures, and reporting obligations. The UAE
FATCA Guidance Notes do not hold the force of law.
The exchange of information is conducted on an annual basis, occurring in September of

each year, between the UAE competent authority and the US IRS. UAE reporting
financial institutions for FATCA purposes need to submit their FATCA returns to their
relevant financial regulator (or the UAE MoF for unregulated entities) by 30 June of
each year (unless otherwise informed). Filing of nil reports is required under FATCA.
Common Reporting Standard (CRS)
On 22 February 2017, the United Arab Emirates signed the Multilateral Competent
Authority Agreement (MCAA) on the Automatic Exchange of Financial Account
Information, and the Convention on Mutual Administrative Assistance in Tax Matters
(MAC) was signed on 21 April 2017.

each year, between the UAE competent authority and competent authorities of
jurisdictions that have agreed to exchange information with the United Arab Emirates.
On 3 August 2020, UAE MoF issued Guidance Notes for CRS purposes (UAE CRS
Guidance Notes). The UAE CRS Guidance Notes do not hold the force of law.
UAE reporting financial institutions for CRS purposes need to submit their CRS returns
to their relevant financial regulators (or the UAE MoF for unregulated entities) by 30
June of each year (unless otherwise informed). Filing of nil reports is required under the
CRS.
Individual - Significant developments

Currently, there are no plans to introduce personal income taxation in the United Arab
Emirates (UAE).
Individual - Taxes on personal income

Absence of taxation
There is currently no personal income tax in the United Arab Emirates. As such, there
are no individual tax registration or reporting obligations.
Under the Federal Decree-Law No. 47 of 2022 on the Taxation on Corporations and
Businesses (‘UAE CT Law’), natural persons who conduct a business or business activity
in the United Arab Emirates will be subject to UAE CT at 9% where the total turnover
derived from such business or business activity exceeds 1 million UAE dirham (AED).
For this purpose, wages, personal investment income, and real estate investment
income will not be considered for determining such turnover.
Local income taxes
There is no federal or Emirate-level personal income tax in the United Arab Emirates.
Individual - Residence
On 9 September 2022, the UAE Cabinet of Ministers issued Decision No. 85 of 2022,
which provides a new domestic definition and criteria for when an individual shall be
considered a tax resident of the United Arab Emirates for the purposes of any UAE tax
law or double tax treaty (DTT). The effective date of the new rules is 1 March 2023.
A natural person will be considered a UAE tax resident if the individual meets any of the
below-mentioned conditions:
• Has one’s usual or primary place of residence and one’s center of financial and
personal interests in the United Arab Emirates.
• Was physically present in the United Arab Emirates for a period of 183 days or
more during a consecutive 12-month period.
• Was physically present in the United Arab Emirates for a period of 90 days or
more in a consecutive 12-month period and is a UAE national, holds a valid
residence permit in the United Arab Emirates, or holds the nationality of any Gulf
Cooperation Council (GCC) member state, where the individual:
o has a permanent place of residence in the United Arab Emirates, or
o carries on an employment or a business in the United Arab Emirates.
Individual - Other taxes

Social security contributions

There is a social security regime in the United Arab Emirates that applies to qualifying
UAE and other GCC national employees only. Non-GCC nationals are not subject to social
security in the United Arab Emirates.
For UAE national employees, social security contributions are calculated at a rate of
20% of the employee's gross remuneration as stated in the local employment contract.
Social security obligations also apply to employees of companies and branches
registered in a free trade zone (FTZ). Out of the 20%, 5% is payable by the employee,
12.5% is payable by the employer, and an additional 2.5% contribution is made by the
government. A higher rate of 26% is applied in the Emirate of Abu Dhabi, where the
contribution of the employer is increased to 15%, the government’s contribution is
increased to 6%, and the employee’s contribution remains 5%.
For other GCC nationals working in the United Arab Emirates, social security
contributions are determined in accordance with the social security regulations of their
home country.
The employer is responsible for withholding and remitting employee social security
contributions.
In the Dubai International Financial Centre (DIFC), the DIFC Employee Workplace
Savings Scheme (DEWS) has been introduced, replacing the End of Service Gratuity
Benefit (EOSG) , with the aim of protecting long-term employee savings. The new
scheme was rolled out on 1 February 2020, and employers now are required to make
monthly contributions to DEWS or an alternative regulated Qualifying Scheme, as
opposed to paying a lump sum ‘gratuity payment’ to an employee at the end of their
employment. Employers are required to contribute monthly contributions of 5.83% or
8.33% of the employee’s basic salary (the actual percentage is contingent upon the
employee’s length of service) into the scheme.
Unemployment insurance scheme
The unemployment insurance scheme introduced in Federal Decree-Law No. 13 of 2022

applies to Emirati and foreign workers and entered into effect on 1 January 2023. The
scheme provides financial support to qualifying individuals in the public and private
sectors in the event of unemployment.
The scheme divides subscribers into two categories: (i) those who earn AED 16,000 or
less as basic salary per month and (ii) those who earn more than AED 16,000 as their
monthly basic salary. Those who fall under the former category are required to pay a
monthly subscription fee of AED 5, while those who fall under the latter category must
pay a monthly subscription fee of AED 10. Given that this is a new law, we are waiting
for further details on the implementation of the scheme. Thus far, the obligation for the
deduction of the monthly subscription fee falls on the employee.
While the scheme is mandatory for Emirati and foreign workers in the private and
public sectors, it does not apply to the following groups:
• Investors.
• Domestic workers.
• Employees contracted on a temporary basis.
• Minors (those under the age of 18).
• Retirees who are already receiving pensions and who have joined a new employer.
Capital gains taxes

There is currently no personal income tax in the United Arab Emirates. As such, capital
gains tax is not imposed on UAE national or resident individuals.
Consumption taxes
Value-added tax (VAT) was implemented in the United Arab Emirates on 1 January
2018.
See Value-added tax in the Other taxes section of the Corporate Tax Summary for more
information.
Net wealth/worth taxes

There are currently no wealth taxes imposed on individuals in the United Arab
Emirates.
Inheritance, estate, and gift taxes
There are currently no inheritance, estate, or gift taxes imposed on individuals in the
Municipal or property tax

Most Emirates impose a municipality tax on properties, mostly by reference to the
annual rental value. It is generally the tenants' obligation to pay the tax. In some cases,
separate fees are payable by both tenants and property owners. For example, in the
Emirate of Dubai, the municipality tax on property is currently imposed at 5% on
annual rental value for commercial properties, also known as 'market fees' (paid by
property owners), and 5% for residential properties, also known as 'housing fees' (paid
by tenants).
A registration fee may be levied on transfer of ownership of land or real property. For
example, a land registration fee is levied in the Emirate of Dubai at a rate of 4% of the
fair market value of the property on any third-party sale (a cost generally shared
between the buyer and seller), payable to the Dubai Land Department. In Dubai, the
registration fee may also apply on the direct or indirect transfer of shares in an entity
that owns real property.
These levies are imposed and administered differently at varying rates by each Emirate.
Luxury taxes
There are currently no luxury taxes levied in the United Arab Emirates.
Excise taxes
On 1 October 2017, the United Arab Emirates implemented an excise tax on tobacco and
tobacco products, carbonated drinks, and energy drinks.
On 1 December 2019, the United Arab Emirates expanded the scope of excise tax to
include sweetened drinks, electronic smoking devices and tools, as well as liquids used
in electronic smoking devices and tools.
The applicable tax rates are as follows:
• 100% on tobacco and tobacco products, electronic smoking devices and tools, liquids
used in electronic smoking devices and tools, and energy drinks.
• 50% on carbonated drinks and sweetened drinks.
Customs duties
Generally, a customs duty of 5% is imposed on the cost, insurance, and freight (CIF)
value of imports. Other rates may apply to certain goods, such as alcohol and tobacco,
and certain exemptions and reliefs may also be available. Further, the United Arab
Emirates imposes anti-dumping duties on imports of certain goods, such as car
batteries, ceramic and porcelain tiles, and hydraulic cement. The anti-dumping duty
rates vary depending on the HS codes of the goods and the country of export and/or
origin. In some cases, the anti-dumping duty is 67.5% of the CIF value of the goods.
The United Arab Emirates is part of the GCC Customs Union, which was established in
2003 to remove customs and trade barriers among the GCC member states. No customs
duties are levied on trade between the GCC member states (subject to certain
conditions). Additionally, the United Arab Emirates grants duty-free imports to most
national goods originating in member countries of the Greater Arab Free Trade
Agreement, Singapore, the European Free Trade Association countries (i.e. Norway,
Switzerland, Iceland, and Liechtenstein), Israel, and India.
While the UAE FTZs are areas within the territory of the United Arab Emirates, these
are, however, considered outside the scope of the customs territory. Therefore, goods
imported into the UAE FTZs are not subject to customs duty. Customs duty is suspended
until the goods are imported into the GCC local market.
Hotel tax and tourism levies

Most Emirates impose hotel levies, which apply on the value of hotel room rental,
services, and entertainment. These levies are imposed and administered differently by
each Emirate.
A Tourism Dirham fee is levied in the Emirate of Dubai. This is a charge on hotel guests
and tenants of hotel apartments ranging from AED 7 to AED 20 per room per night
depending on the star classification of the hotel, for example, a five-star hotel will levy a
Tourism Dirham fee equal to AED 20 per room per night whereas a two-star hotel will
levy a Tourism Dirham fee equal to AED 10 per room per night. In the Emirate of Abu
Dhabi, hotels will levy a tourism fee equal to 6% of the hotel room rental and a
destination fee of AED 15 per night.
In addition to the above tourism fees, the Emirate of Dubai also requires hotels to levy a
7% municipality fee on each hotel sale. The Emirate of Dubai does not impose
destination fees. Likewise, in the Emirate of Abu Dhabi, hotels are required to levy a 4%
municipality fee. A hotel sale is revenue generated by a hotel for services provided to
their guests or visitors, which includes rent for the hotel room, food, beverages, and
other services.
Hotels in all Emirates levy an additional service charge equivalent to 10% of the hotel
sale revenue.
Individual - Income determination
Absence of taxation
There is currently no personal income tax in the United Arab Emirates.
Individual - Deductions
Absence of taxation
As there is currently no personal income tax in the United Arab Emirates, tax deductions
are not applicable.
Individual - Foreign tax relief and tax treaties

Foreign tax relief

As there is currently no personal income tax in the United Arab Emirates, claiming relief
for foreign taxes paid is not applicable.
Tax treaties
UAE nationals or resident individuals and UAE resident companies have access to an
extensive and growing DTT network. The DDT could allow for relief from taxation in
DTT partner countries. The DTTs currently in force are listed below. Many other DTTs
are at various stages of negotiation and ratification.
Albania Guinea Pakistan
Algeria Hong Kong Panama
Andorra Hungary Paraguay
Angola India Philippines
Argentina Indonesia Poland

Armenia Ireland Portugal
Austria Israel Romania
Azerbaijan Italy Russia (1)
Bangladesh Japan Saudi Arabia
Barbados Jersey Senegal
Belarus Jordan Serbia
Belgium Kazakhstan Seychelles
Belize Kenya Singapore
Bermuda Korea, Republic of Slovakia
Bosnia and Herzegovina Kosovo Slovenia
Botswana Kyrgyzstan South Africa
Brazil Latvia Spain
Brunei Lebanon Sri Lanka
St. Vincent &

Bulgaria Liechtenstein
the Grenadines
Cameroon Lithuania Sudan

Canada Luxembourg Switzerland
China, People’s Republic of Malaysia Syria
Comoro Islands Maldives Tajikistan
Costa Rica Malta Thailand
Croatia Mauritania Tunisia
Cyprus Mauritius Turkey
Czech Republic Mexico Turkmenistan
Egypt Moldova Ukraine
United
Estonia Montenegro
Kingdom
Ethiopia Morocco Uruguay
Fiji Mozambique Uzbekistan
Finland Netherlands Venezuela
France New Zealand Vietnam
Georgia Niger Yemen
Greece North Macedonia Zimbabwe

Notes
1. Government institutions only.
Individual - Tax Administration

Absence of taxation
There is currently no federal or Emirate-level personal income tax in the United Arab
Emirates. Accordingly, there are no individual tax registration or reporting obligations.
Individual - Sample personal income tax calculation

Absence of taxation
Individual - Other issues

Exchange control
There are no foreign exchange control restrictions in the United Arab Emirates that may
impact cross-border remittances.
Immigration and visa rules

A visa or residency permit is required to live or work in the United Arab Emirates. Long-
term visas and residency permits can be obtained on the basis of investment, ownership
of a business, or on the basis of an employment contract with a UAE employer.
Separate rules apply for business, tourist, and other visas.

United States (US) Foreign Account Tax Compliance Act
(FATCA)
On 17 June 2015, the United Arab Emirates signed the Model 1B Intergovernmental
Agreement (IGA) with the United States, which came into force on 19 February 2016
(US-UAE Model 1 IGA), with the US Internal Revenue Services (IRS) regarding the
exchange of information related to US individuals and certain type of US-owned entities,
with an effective date of 1 July 2014.
On 6 July 2015, the UAE Ministry of Finance (MoF) issued guidance notes on the
requirements of the US-UAE Model 1 IGA on the implementation of FATCA (UAE FATCA
Guidance Notes). The UAE FATCA Guidance Notes expand upon the UAE-US Model 1
IGA, including the definitions, implementation of the due diligence procedures, and
reporting obligations. The UAE FATCA Guidance Notes do not hold the force of law.

each year, between the UAE competent authority and the US IRS. UAE reporting
financial institutions for FATCA purposes need to submit their FATCA returns to their
relevant financial regulator (or the UAE MoF for unregulated entities) by 30 June of
each year (unless otherwise informed). Filing of nil reports is required under FATCA.
Common Reporting Standard (CRS)

On 22 February 2017, the United Arab Emirates signed the Multilateral Competent
Authority Agreement (MCAA) on the Automatic Exchange of Financial Account
Information, and the Convention on Mutual Administrative Assistance in Tax Matters
(MAC) was signed on 21 April 2017.

each year, between the UAE competent authority and competent authorities of
jurisdictions that have agreed to exchange information with the United Arab Emirates.
On 3 August 2020, the UAE MoF issued Guidance Notes for CRS purposes (UAE CRS
Guidance Notes). The UAE CRS Guidance Notes do not hold the force of law.
UAE reporting financial institutions for CRS purposes need to submit their CRS returns
to their relevant financial regulators (or the UAE MoF for unregulated entities) by 30
June of each year (unless otherwise informed). Filing of nil reports is required under the
CRS.

United Arab Emirates - CORPORATE TAX

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United Arab Emirates - CORPORATE TAX

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The United Arab Emirates has a well-established infrastructure, a stable political

Quick rates and dates

Headline CIT rate (%) 9

Corporate income tax (CIT) due dates

Under the UAE CT Law, all taxable persons are

Under the UAE CT Law, all taxable persons are

Headline PIT rate (%) NA

Personal income tax (PIT) due dates

PIT return due date NA

PIT final payment due date NA

PIT estimated payment due dates NA

Value-added tax (VAT) rates

Standard VAT rate (%) 5

Withholding tax (WHT) rates

WHT rates (%) 0% WHT in case of certain categories of UAE-sourced

Capital gains tax (CGT) rates

Headline corporate capital gains Same as UAE CT rates, where participation

Headline individual capital gains

Net wealth/worth tax rates

Headline net wealth/worth tax rate

Inheritance and gift tax rates

Headline inheritance tax rate (%) NA

Headline gift tax rate (%) NA

Corporate - Significant developments

Economic substance regulations

Corporate - Taxes on corporate income

• UAE government entity.

UAE CT will be applicable at the following rates:

Taxable income UAE CT rate (%)

• Taxable income not exceeding 375,000 UAE dirham

• Taxable income exceeding AED 375,000.

Corporate - Corporate residence

• has a permanent establishment (PE) in the United Arab Emirates

Permanent establishment (PE)

In terms of the UAE CT law, a non-resident person would generally be considered to

• Such a presence is a consequence of a temporary and exceptional situation.

Corporate - Other taxes

Value-added tax (VAT)

A VAT exemption applies to certain financial services, as well as to the subsequent

Certain transactions in goods between companies established in UAE Designated (Free)

VAT grouping is allowed, provided certain conditions are met.

There are specific documentary and record-keeping requirements, such as the

The applicable tax rates are as follows:

Municipal or property tax

Social security contributions

Under UAE CT Law, a branch of a non-resident person could be regarded as a PE in the

Corporate - Income determination

Resident person Tax base

An entity that is incorporated in the United Arab

A foreign entity that is effectively managed and

A natural person/individual who conducts a

Any other person (may be determined by a Cabinet

Non-resident person Tax base

Taxable income attributable

The UAE-sourced income

Taxable income attributable

Unrealized gains or losses

Dividends and other profit distributions relating to an ownership interest (referred to

• the ownership interest is at least 5%