Corporate Tax Law

Definitions – Article 1 – Corporate Tax Law

Article 1 – Definitions In the application of the provisions of this Decree-Law, the following words and expressions shall have the meanings assigned against each,...

Imposition of Corporate Tax – Article 2 – Corporate Tax Law

Article 2 – Imposition of Corporate Tax Corporate Tax shall be imposed on Taxable Income, at the rates determined under this Decree-Law, and payable to...

Corporate Tax Rate – Article 3 – Corporate Tax Law

Article 3 – Corporate Tax Rate Corporate Tax shall be imposed on the Taxable Income at the following rates: 0% (zero percent) on the portion...

Exempt Person – Article 4 – Corporate Tax Law

Article 4 – Exempt Person The following Persons shall be exempt from Corporate Tax: A Government Entity. A Government Controlled Entity. A Person engaged in...

Government Entity – Article 5 – Corporate Tax Law

Article 5 – Government Entity A Government Entity shall be exempt from Corporate Tax and the provisions of this Decree-Law shall not apply to it....

Government Controlled Entity – Article 6 – Corporate Tax Law

Article 6 – Government Controlled Entity A Government Controlled Entity shall be exempt from Corporate Tax and the provisions of this Decree-Law shall not apply...

Extractive Business – Article 7 – Corporate Tax Law

Article 7 – Extractive Business A Person shall be exempt from Corporate tax and the provisions of this Decree-Law shall not apply to its Extractive...

Non-Extractive Natural Resource Business – Article 8 – Corporate Tax Law

Article 8 – Non-Extractive Natural Resource Business A Person shall be exempt from Corporate tax and the provisions of this Decree-Law shall not apply to...

Qualifying Public Benefit Entity – Article 9 – Corporate Tax Law

Article 9 – Qualifying Public Benefit Entity A Qualifying Public Benefit Entity shall be exempt from Corporate Tax where all of the following conditions are...

Qualifying Investment Fund – Article 10 – Corporate Tax Law

Article 10 – Qualifying Investment Fund An investment fund may apply to the Authority to be exempt from Corporate Tax as a Qualifying Investment Fund...

Taxable Person – Article 11 – Corporate Tax Law

Article 11 – Taxable Person Corporate Tax shall be imposed on a Taxable Person at the rates determined under this Decree-Law. For the purposes of...

State Sourced Income – Article 13 – Corporate Tax Law

Article 13 – State Sourced Income Income shall be considered State Sourced Income in any of the following instances: Where it is derived from a...

Permanent Establishment – Article 14 – Corporate Tax Law

Article 14 – Permanent Establishment A Non-Resident Person has a Permanent Establishment in the State in any of the following instances: Where it has a...

Investment Manager Exemption – Article 15 – Corporate Tax Law

Article 15 – Investment Manager Exemption 1. For the purposes of Clause 6 of Article 14 of this Decree-Law, an Investment Manager shall be considered...

Partners in an Unincorporated Partnership – Article 16 – Corporate Tax Law

Article 16 – Partners in an Unincorporated Partnership 1. Unless an application is made under Clause 8 of this Article, and subject to any conditions...

Family Foundation – Article 17 – Corporate Tax Law

Article 17 – Family Foundation 1. A Family Foundation can make an application to the Authority to be treated as an Unincorporated Partnership for the...

Qualifying Free Zone Person – Article 18 – Corporate Tax Law

Article 18 – Qualifying Free Zone Person 1. A Qualifying Free Zone Person is a Free Zone Person that meets all of the following conditions:...

Election to be Subject to Corporate Tax – Article 19 – Corporate Tax Law

Article 19 – Election to be Subject to Corporate Tax 1. A Qualifying Free Zone Person can make an election to be subject to Corporate...

General Rules for Determining Taxable Income – Article 20 – Corporate Tax Law

Article 20 – General Rules for Determining Taxable Income 1. The Taxable Income of each Taxable Person shall be determined separately, on the basis of...

Small Business Relief – Article 21 – Corporate Tax Law

Article 21 – Small Business Relief 1. A Taxable Person that is a Resident Person may elect to be treated as not having derived any...

Exempt Income – Article 22 – Corporate Tax Law

Article 22 – Exempt Income The following income and related expenditure shall not be taken into account in determining the Taxable Income: Dividends and other...

Participation Exemption – Article 23 – Corporate Tax Law

Article 23 – Participation Exemption 1. Income from a Participating Interest shall be exempt from Corporate Tax, subject to the conditions of this Article. 2....

Foreign Permanent Establishment Exemption – Article 24 – Corporate Tax Law

Article 24 – Foreign Permanent Establishment Exemption 1. A Resident Person can make an election to not take into account the income, and associated expenditure,...

Non-Resident Person Operating Aircraft or Ships in International Transportation – Article 25 – Corporate Tax Law

Article 25 – Non-Resident Person Operating Aircraft or Ships in International Transportation Income derived by a Non-Resident Person from the operation of aircraft or ships...

Transfers Within a Qualifying Group – Article 26 – Corporate Tax Law

Article 26 – Transfers Within a Qualifying Group 1. No gain or loss needs to be taken into account in determining the Taxable Income in...

Business Restructuring Relief – Article 27 – Corporate Tax Law

Article 27 – Business Restructuring Relief 1. No gain or loss needs to be taken into account in determining Taxable Income in any of the...

Deductible Expenditure – Article 28 – Corporate Tax Law

Article 28 – Deductible Expenditure 1. Expenditure incurred wholly and exclusively for the purposes of the Taxable Person’s Business that is not capital in nature...

Interest Expenditure – Article 29 – Corporate Tax Law

Article 29 – Interest Expenditure Notwithstanding paragraph (b) of Clause 2 of Article 28 of this Decree-Law, Interest expenditure shall be deductible in the Tax...

General Interest Deduction Limitation Rule – Article 30 – Corporate Tax Law

Article 30 – General Interest Deduction Limitation Rule 1. A Taxable Person’s Net Interest Expenditure shall be deductible up to 30% (thirty percent) of the...

Specific Interest Deduction Limitation Rule – Article 31 – Corporate Tax Law

Article 31 – Specific Interest Deduction Limitation Rule 1. No deduction shall be allowed for Interest expenditure incurred on a loan obtained, directly or indirectly,...

Entertainment Expenditure – Article 32 – Corporate Tax Law

Article 32 – Entertainment Expenditure 1. Subject to Article 28 of this Decree-Law, a Taxable Person shall be allowed to deduct 50% (fifty percent) of...

Non-deductible Expenditure – Article 33 – Corporate Tax Law

Article 33 – Non-deductible Expenditure No deduction is allowed for: Donations, grants or gifts made to an entity that is not a Qualifying Public Benefit...

Arm’s Length Principle – Article 34 – Corporate Tax Law

Article 34 – Arm’s Length Principle 1. In determining Taxable Income, transactions and arrangements between Related Parties must meet the arm’s length standard as specified...

Related Parties and Control – Article 35 – Corporate Tax Law

Article 35 – Related Parties and Control 1. For the purposes of this Decree-Law, “Related Parties” means any of the following: Two or more natural...

Payments to Connected Persons – Article 36 – Corporate Tax Law

Article 36 – Payments to Connected Persons 1. Without prejudice to the provisions of Article 28 of this Decree-Law, a payment or benefit provided by...

Tax Loss Relief – Article 37 – Corporate Tax Law

Article 37 – Tax Loss Relief 1. A Tax Loss can be offset against the Taxable Income of subsequent Tax Periods to arrive at the...

Transfer of Tax Loss – Article 38 – Corporate Tax Law

Article 38 – Transfer of Tax Loss 1. A Tax Loss or a portion thereof may be offset against the Taxable Income of another Taxable...

Tax Group – Article 40 – Corporate Tax Law

Article 40 – Tax Group 1. A Resident Person, which for the purposes of this Decree-Law shall be referred to as a “Parent Company”, can...

Date of Formation and Cessation of a Tax Group – Article 41 – Corporate Tax Law

Article 41 – Date of Formation and Cessation of a Tax Group 1. For the purposes of Article 40 of this Decree-Law, a Tax Group...

Taxable Income of a Tax Group – Article 42 – Corporate Tax Law

Article 42 – Taxable Income of a Tax Group 1. For the purposes of determining the Taxable Income of a Tax Group, the Parent Company...

Currency – Article 43 – Corporate Tax Law

Article 43 – Currency For the purposes of this Decree-Law, all amounts must be quantified in the United Arab Emirates dirham. Any amount quantified in...

Calculation and Settlement of Corporate Tax – Article 44 – Corporate Tax Law

Article 44 – Calculation and Settlement of Corporate Tax The Corporate Tax due under this Decree-Law is settled in the following order: First, by using...

Withholding Tax – Article 45 – Corporate Tax Law

Article 45 – Withholding Tax 1. The following income shall be subject to Withholding Tax at the rate of 0% (zero percent) or any other...

Withholding Tax Credit – Article 46 – Corporate Tax Law

Article 46 – Withholding Tax Credit 1. If a Person becomes a Taxable Person in a Tax Period, the Person’s Corporate Tax due under Article...

Foreign Tax Credit – Article 47 – Corporate Tax Law

Article 47 – Foreign Tax Credit 1. Corporate Tax due under Article 3 of this Decree-Law can be reduced by the amount of Foreign Tax...

Corporate Tax Payment – Article 48 – Corporate Tax Law

Article 48 – Corporate Tax Payment A Taxable Person must settle the Corporate Tax Payable under this Decree-Law within (9) nine months from the end...

Corporate Tax Refund – Article 49 – Corporate Tax Law

Article 49 – Corporate Tax Refund 1. A Taxable Person may make an application to the Authority for a Corporate Tax refund in accordance with...

General anti-abuse rule – Article 50 – Corporate Tax Law

Article 50 – General anti-abuse rule 1. This Article applies to a transaction or an arrangement if, having regard to all relevant circumstances, it can...

Tax Registration – Article 51 – Corporate Tax Law

Article 51 – Tax Registration 1. Any Taxable Person shall register for Corporate Tax with the Authority in the form and manner and within the...

Tax Deregistration – Article 52 – Corporate Tax Law

Article 52 – Tax Deregistration 1. A Person with a Tax Registration Number shall file a Tax Deregistration application with the Authority where there is...

Tax Returns – Article 53 – Corporate Tax Law

Article 53 – Tax Returns 1. Subject to Article 51 of this Decree-Law, a Taxable Person must file a Tax Return, as applicable, to the...

Financial Statements – Article 54 – Corporate Tax Law

Article 54 – Financial Statements 1. The Authority may, by notice or through a decision issued by the Authority, request a Taxable Person to submit...

Transfer Pricing Documentation – Article 55 – Corporate Tax Law

Article 55 – Transfer Pricing Documentation 1. The Authority may, by notice or through a decision issued by the Authority, require a Taxable Person to...

Record Keeping – Article 56 – Corporate Tax Law

Article 56 – Record Keeping 1. Notwithstanding the provisions of the Tax Procedures Law, a Taxable Person shall maintain all records and documents for a...

Tax Period – Article 57 – Corporate Tax Law

Article 57 – Tax Period 1. A Taxable Person’s Tax Period is the Financial Year or part thereof for which a Tax Return is required...

Change of Tax Period – Article 58 – Corporate Tax Law

Article 58 – Change of Tax Period Notwithstanding Article 57 of this Decree-Law, a Taxable Person can make an application to the Authority to change...

Clarifications – Article 59 – Corporate Tax Law

Article 59 – Clarifications 1. A Person may make an application to the Authority for a clarification regarding the application of this Decree-Law or the...

Assessment of Corporate Tax and penalties – Article 60 – Corporate Tax Law

Article 60 – Assessment of Corporate Tax and penalties 1. A Person may be subject to a Corporate Tax assessment in accordance with the Tax...

Transitional Rules – Article 61 – Corporate Tax Law

Article 61 – Transitional Rules 1. A Taxable Person’s opening balance sheet for Corporate Tax purposes shall be the closing balance sheet prepared for financial...

Delegation of Power – Article 62 – Corporate Tax Law

Article 62 – Delegation of Power The Minister may delegate his powers under this Decree-Law, in full or in part, to the Authority, where the...

Administrative Policies and Procedures – Article 63 – Corporate Tax Law

Article 63 – Administrative Policies and Procedures The administrative policies, procedures and general instructions in relation to the requirements imposed on a Person under this...

Cooperating with the Authority – Article 64 – Corporate Tax Law

Article 64 – Cooperating with the Authority All governmental authorities in the State shall fully cooperate with the Authority to carry out whatever is required...

Revenue Sharing – Article 65 – Corporate Tax Law

Article 65 – Revenue Sharing Corporate Tax revenues and Administrative Penalties collected under this Decree-Law shall be subject to sharing between the Federal Government and...

International Agreements – Article 66 – Corporate Tax Law

Article 66 – International Agreements To the extent the terms of an international agreement that is in force in the State are inconsistent with the...

Cancellation of Conflicting Provisions – Article 68 – Corporate Tax Law

Article 68 – Cancellation of Conflicting Provisions Any text or provisions contrary to or inconsistent with the provisions of this Decree-Law shall be abrogated.

Application of this Decree-Law to Tax Periods – Article 69 – Corporate Tax Law

Article 69 – Application of this Decree-Law to Tax Periods This Decree-Law shall apply to Tax Periods commencing on or after 1 June 2023.

Publication and Application of this Decree-Law – Article 70 – Corporate Tax Law

Article 70 – Publication and Application of this Decree-Law This Decree-Law shall be published in the Official Gazette and shall come into effect (15) fifteen...

Corporate Tax Base – Article 12 – Corporate Tax Law

Article 12 – Corporate Tax Base A Resident Person, which is a juridical person, is subject to Corporate Tax on its Taxable Income derived from...

Limitation on Tax Losses Carried Forward – Article 39 – Corporate Tax Law

Article 39 – Limitation on Tax Losses Carried Forward 1. Tax Losses can only be carried forward and utilised in accordance with the provision of...

Implementing Decisions – Article 67 – Corporate Tax Law

Article 67 – Implementing Decisions 1. Subject to the powers conferred to the Cabinet under this Decree-Law, the Minister and the Authority shall issue the...