Article 1 - Definitions
Words and expressions in this Decision shall have the same meanings specified in the Cabinet Decision No. 85 of 2022 on Determination of Tax Residency unless the context requires otherwise.
Website Last updated:
May 15, 2026
This is not an Official Translation:
Implementation of Certain Provisions of Cabinet Decision No. 85 of 2022 on Determination of Tax Residency
Ministerial Decision No. 27 of 2023
Issued 22 Feb 2023 - (Effective 1 Mar 2023)
[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 the 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,
Cabinet Decision No. 85 of 2022 on Determination of Tax Residency,
Article 2 - Usual or Primary Place of Residence and Centre of Financial and Personal Interests in the State
A natural person' usual or primary place of residence is in the State if the State is the jurisdiction where the natural person habitually or normally resides.
The place where the natural person habitually or normally resides is the jurisdiction where he spends most of his time when compared to any other jurisdiction as part of his settled routine in a way that is more than transient and that should be taken into account in the determination of whether a natural person's usual or primary place of residence is in the State.
A natural person's centre of financial and personal interests is in the State if the State is the jurisdiction where the natural person’s personal and economic interests are the closest or of the greatest significance to the natural person.
The place of the natural person's occupation, familial and social relations, cultural or other activities, place of business, place from which the property of the natural person is administered and any other relevant facts and circumstances should be taken into account in the determination of whether a natural person's centre of financial and personal interests is in the State.