Website Last updated:

May 15, 2026

This guide clarifies the conditions for exemption from UAE Corporate Tax for specific entities under Article 4. It focuses on Qualifying Public Benefit Entities, explaining the operational and purpose-driven requirements detailed in Article 9. The guide also outlines exemption criteria for public and private pension and social security funds. It explains how subsidiaries of these exempt funds may also qualify for exemption under Article 4(1)(h) if specific conditions are met. The guide further addresses the procedural aspects of registration and the consequences of failing to meet exemption conditions, ensuring compliance for these specialized entities.

Exempt Persons: Public Benefit Entities, Pension Funds and Social Security Funds

Corporate Tax Guide | CTGEPF1

December 2023

1. Glossary

2. Introduction

2.1. Overview
2.2. Purpose of this guide
2.3. Who should read this guide?
2.4. How to use this guide
2.5. Legislative references
2.6. Status of this guide

3. What is an Exempt Person?

4. Qualifying Public Benefit Entities

4.1. Conditions for meeting Qualifying Public Benefit Entity status
1. 4.1.1. Establishment and operation purpose
  4.1.2. Business or Business Activity condition
  4.1.3. Income and assets condition
  4.1.4. No personal benefit conditions
  4.1.5. Listed in a Cabinet decision
  4.1.6. Monitoring compliance
  4.1.7. Effective date of exemption
4.2. Payments to a Qualifying Public Benefit Entity

5. Public and private pension funds and social security funds

5.1. Public pension funds and social security funds
5.2. Private pension funds and social security funds
1. 5.2.1. Purpose
  5.2.2. Application requirements and process to be an Exempt Person
5.3. Subsidiary of a public or private fund or social security fund
5.4. Contributions to a pension or social security fund

6. Failure to meet the conditions of an Exempt Person

6.1. Liquidation or termination
6.2. Failure is of temporary nature which is promptly rectified
6.3. Failure is to obtain Corporate Tax advantage

7. Corporate Tax consequences of benefitting from Exempt Person status

7.1. No availability of Small Business Relief
7.2. No availability of Qualifying Group Relief or Business Restructuring Relief
7.3. No transfer of Tax Loss
7.4. Exempt Person cannot be a member of a Tax Group

8. Compliance Requirements

8.1. Tax Registration
8.2. Application for exemption and applicable timelines
8.3. Administration
8.4. Confirmation by the Auditor
8.5. Record keeping required to maintain Exempt Person status

9. Updates and Amendments

Contents

Glossary