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May 15, 2026

This guide explains the specific Corporate Tax exemptions available to Extractive and Non-Extractive Natural Resource Businesses under Articles 7 and 8. It clarifies their status as Exempt Persons per Article 4, respecting Emirate-level sovereignty and taxation. The guide details the core conditions for exemption, including holding a right or interest in UAE natural resources and being subject to Emirate-level taxation. It further establishes the tax treatment for other Business Activities, defining rules for ancillary income and the apportionment of common expenditures, ensuring a clear delineation between exempt and taxable income streams.

Taxation of Extractive Business and Non-Extractive Natural Resource Business

Corporate Tax Guide | CTGEPX1

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. Scope of Extractive Business and Non-Extractive Natural Resource Business

3.1. What are Natural Resources?
3.2. What is an Extractive Business?
3.3. What is a Non-Extractive Natural Resource Business?
3.4. Other Business
3.5. Process for exploiting Natural Resources

4. Taxation of Extractive Business and Non-Extractive Natural Resource Business

4.1. Introduction
4.2. Conditions to qualify as an Exempt Person
1. 4.2.1. Directly or indirectly holding or having an interest in a right, concession or Licence
  4.2.2. Effectively subject to Emirate-level taxation
  4.2.3. Notification to the Ministry of Finance
  4.2.4. Solely deriving income from Persons undertaking Business or Business Activity
4.3. Exceptional cases of failure to meet conditions of Exempt Person
1. 4.3.1. Liquidation or termination
  4.3.2. Failure to meet condition is of temporary nature which is promptly rectified
  4.3.3. Failure to meet the conditions is to obtain a Corporate Tax advantage
4.4. Income derived from other Business
4.5. Exemption for other Business
1. 4.5.1. Ancillary or incidental Business
  4.5.2. Revenue not exceeding five percent of the total Revenue

5. Determination of Taxable Income of other Business

5.1. Treatment as separate entities
1. 5.1.1. Other Business treated independently
  5.1.2. Taxable Income calculated independently
5.2. Apportionment of expenditure
1. 5.2.1. Apportionment of common expenditure
5.3. Adjustments to determine Taxable Income
1. 5.3.1. Provisions applicable to the Exempt Person's other Business
  5.3.2. Provisions not applicable to the Exempt Person's Business
5.4. Small Business Relief
5.5. Exempt Persons registered in Free Zones

6. Compliance Requirements

6.1. Record keeping
6.2. Tax Registration
6.3. Applicable Accounting Standards
6.4. Preparing audited Financial Statements
6.5. Tax Return

7. Updates and Amendments

Contents

Glossary