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May 15, 2026

This Decision established the original conditions for the tax treatment of partnerships and foundations under Articles 16 and 17 of the Corporate Tax Law. It stipulated that an Unincorporated Partnership opting to be a Taxable Person must notify the Authority of any partner changes within 20 business days. For a Foreign Partnership to be treated as an Unincorporated Partnership, it required an annual declaration and adequate tax information sharing arrangements with its home jurisdiction. This legislation has since been entirely repealed and is no longer in effect, having been superseded by a subsequent decision.

[Repealed by Ministerial Decision No. 261 of 2024]

This is not an Official Translation:

Unincorporated Partnership, Foreign Partnership and Family Foundation for the Purposes of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses

Ministerial Decision No. 127 of 2023

Issued 24 May 2023 – (Effective from the day after publishing in the Official Gazette)

[GTL Notes]

The Minister of State for Financial Affairs has decided:

Having reviewed the Constitution,
Federal Law No. 1 of 1972 on the Competencies of Ministries and Powers of the Ministers, and its amendments,
Federal Decree-Law No. 13 of 2016 on the Establishment of the Federal Tax Authority, and its amendments,
Federal Decree-Law No. 28 of 2022 on Tax Procedures,
Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses,

Article 1 - Definitions

Words and expressions in this Decision shall have the same meanings specified in the Federal Decree-Law No. 47 of 2022 referred to above ('Corporate Tax Law'), unless the context requires otherwise.

Article 2 - Conditions for an Unincorporated Partnership not to be Considered a Taxable Person in its Own Right

For the purposes of Clause (1) of Article 16 of the Corporate Tax Law, and without prejudice to Clause (7) of Article 16 and Article 17 of the Corporate Tax Law, the Unincorporated Partnership shall not be considered as a Taxable Person in its own right, provided it is not a juridical person.

Article 3 - Treatment of the Unincorporated Partnership as a Taxable Person

Where an application for the Unincorporated Partnership to be treated as a Taxable Person in its own right under Clause (8) of Article 16 of the Corporate Tax Law is approved, the following shall apply:

The application shall be deemed irrevocable, except under exceptional circumstances and pursuant to the approval by the Authority.
The Unincorporated Partnership shall notify the Authority within (20) twenty business days from the occurrence of any of the following circumstances:
1. Any partner joining the Unincorporated Partnership.
2. Any partner leaving the Unincorporated Partnership.

The Minister of State for Financial Affairs has decided:

Article 1 - Definitions

Article 2 - Conditions for an Unincorporated Partnership not to be Considered a Taxable Person in its Own Right

Article 3 - Treatment of the Unincorporated Partnership as a Taxable Person

Article 4 - Other Conditions for a Foreign Partnership to be Treated as an Unincorporated Partnership