This Decision establishes conditions for partnerships and foundations pursuant to Articles 16, 17, and 53 of the Corporate Tax Law. It stipulates an Unincorporated Partnership is not a Taxable Person unless it opts for this status, which is irrevocable. A key change is that partner changes must now be reported only with the annual Tax Return, replacing the previous 20-day rule. For Foreign Partnerships, a key condition is not being subject to a similar tax in their home jurisdiction. For Family Foundations with public benefit entity beneficiaries, specific conditions on income derivation and distribution apply. This Decision repeals Ministerial Decision No. 127 of 2023.
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. 261 of 2024
Issued 28 Oct 2024 - (Effective from 1 June 2023)
[GTL Notes]
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