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 this Decree-Law, a Taxable Person shall be either a Resident Person or a Non-Resident Person.

A Resident Person is any of the following Persons:

1. A juridical person that is incorporated or otherwise established or recognised under the applicable legislation of the State, including a Free Zone Person.

2. A juridical person that is incorporated or otherwise established or recognised under the applicable legislation of a foreign jurisdiction that is effectively managed and controlled in the State.

3. A natural person who conducts a Business or Business Activity in the State.

4. Any other Person as may be determined in a decision issued by the Cabinet at the suggestion of the Minister.

A Non-Resident Person is a Person who is not considered a Resident Person under Clause 3 of this Article and that either:

1. Has a Permanent Establishment in the State as under Article 14 of this Decree-Law.

2. Derives State Sourced Income as under Article 13 of this Decree-Law.

3. Has a nexus in the State as specified in a decision issued by the Cabinet at the suggestion of the Minister.

A branch in the State of a Person referred to in Clause 3 of this Article, shall be treated as one and the same Taxable Person.

The Cabinet shall, upon a suggestion of the Minister and in coordination with the relevant competent authorities, issue a decision specifying the categories of Business or Business Activity conducted by a resident or non-resident natural person that are subject to Corporate Tax under this Decree-Law.