Article 24 provides an elective exemption for Resident Persons on the income of their Foreign Permanent Establishments (FPEs). A taxpayer can choose not to include the profits or losses of its FPEs in its UAE Taxable Income calculation. This election applies to all FPEs of the resident person, provided the FPE is subject to a corporate tax (or similar) of at least 9% in its foreign jurisdiction. If the election is made, the taxpayer cannot claim a foreign tax credit for taxes paid by the FPE and must treat transfers between the head office and FPE at market value.