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May 15, 2026

Part 4 - Avoidance of Double Taxation

Chapter 2 - Tax Avoidance between Persons or By Entering into Transactions

Section 2 - Cases of Avoidance by Entering into Transactions

Article 130

[GTL Notes: Company Incorporation Exception]

The provisions of this Section shall not apply to any transaction the main purpose of which is to incorporate a company for the purpose of carrying on a business which has been carried on by a natural person.