This article provides a tax exemption for income derived by a Non-Resident Person from operating aircraft or ships in international transportation. The exemption covers the international transport of passengers and goods, as well as the leasing of aircraft, ships, or related essential equipment. This relief is granted on a reciprocal basis. The key condition is that a UAE Resident Person performing the same activities would be exempt from a similar corporate tax in the Non-Resident Person's home country. This provision aligns with international tax treaty principles to avoid double taxation on international transport income.
Chapter 7 - Exempt Income
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 in international transportation shall not be subject to Corporate Tax where all of the following conditions are met:
The Non-Resident Person is in the Business of any of the following:
International transport of passengers, livestock, mail, parcels, merchandise or goods by air or by sea.
Leasing or chartering aircrafts or ships used in international transportation.
Leasing of equipment which are integral to the seaworthiness of ships or the airworthiness of aircrafts used in international transportation.
A Resident Person that performs any of the activities under Clause 1 of this Article would be exempt, or not be subject to tax that is of a similar character to Corporate Tax, under the applicable legislation of the country or territory in which the Non-Resident Person is resident.
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