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 otherwise requires.
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May 15, 2026
[Repeals Ministerial Decision No. 127 of 2023]
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. 261 of 2024
Issued 28 Oct 2024 - (Effective from 1 June 2023)
[GTL Notes]
Minister of State for Financial Affairs:
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. 47 of 2022 on the Taxation of Corporations and Businesses, and its amendments;
Ministerial Decision No. 127 of 2023 on 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,
Has decided:
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, an Unincorporated Partnership shall not be considered a Taxable Person in its own right unless it is a juridical person.
Article 3 - Treatment of an Unincorporated Partnership as a Taxable Person
Where the Authority approves an application submitted to it for an Unincorporated Partnership to be treated as a Taxable Person in its own right under Clause (8) of Article 16 of the Corporate Tax Law, the application shall be irrevocable, except in exceptional circumstances and pursuant to approval by the Authority.
Where an Unincorporated Partnership is treated as a Taxable Person in its own right in accordance with Clause (8) of Article 16 of the Corporate Tax Law, the responsible partner pursuant to paragraph (c) of Clause (9) of Article 16 of the Corporate Tax Law shall provide the Authority with details of any partner who joins or leaves the Unincorporated Partnership during the relevant Tax Period, when filing the Tax Return as per Article 53 of the Corporate Tax Law.