Corporate Tax - General Guide

Contents

1. Glossary

2. Introduction

1. 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. Getting Additional Help

1. 3.1. Government support channels

4. What is Corporate Tax?

1. 4.1. Chapter summary

   4.2. What is Corporate Tax?

   4.3. How does Corporate Tax work?

5. Who is subject to Corporate Tax?

1. 5.1. Chapter summary

   5.2. Taxable Persons

   5.3. Resident Taxable Persons

   1. 5.3.1. Resident juridical persons

      5.3.2. Effective management and control

      5.3.3. Resident natural persons

      5.3.4. Impact of Double Taxation Agreements on Resident Taxable Persons

   5.4. Non-Resident Taxable Persons

   1. 5.4.1. Non-Resident Person with a Permanent Establishment in the UAE

      5.4.2. Preparatory and auxiliary activities

      5.4.3. Non-Resident Person that derives State Sourced Income

      5.4.4. Non-resident juridical person that has a nexus in the UAE (derives income from UAE Immovable Property)

      5.4.5. Impact of Double Taxation Agreements on Non-Resident Taxable Persons

   5.5. Free Zone Persons

   1. 5.5.1. Qualifying Income

      5.5.2. Excluded Activities

      5.5.3. Qualifying Activities

      5.5.4. Adequate substance requirements

      5.5.5. The de minimis requirement

      5.5.6. Election to be taxed at the general rates of Corporate Tax

   5.6. Family Foundations

   5.7. Exempt Persons

   1. 5.7.1. Types of Exempt Persons

      5.7.2. Automatically Exempt Persons

      5.7.3. Exempt Persons if they notify the Ministry and meet relevant conditions

      5.7.4. Exempt if listed in a Cabinet Decision and meet relevant conditions

      5.7.5. Exempt Persons upon application to the FTA

      5.7.6. Registration and record keeping obligations of Exempt Persons

6. What is subject to Corporate Tax?

1. 6.1. Chapter summary

   6.2. Taxable Income

   1. 6.2.1. Tax Period

      6.2.2. Adjustments

   6.3. Unrealised gains and losses

   1. 6.3.1. Election to use the Realisation Basis

   6.4. Exempt Income

   1. 6.4.1. Domestic dividends

      6.4.2. Income exempt under the participation exemption

      6.4.3. Foreign Permanent Establishment exemption

      6.4.4. Income from operating aircraft or ships in international transportation

   6.5. Deductions

   1. 6.5.1. General deductibility rules

      6.5.2. Wholly and exclusively incurred expenditure

      6.5.3. Capital expenditure

      6.5.4. Special rules for the deductibility of certain expenses

      6.5.5. Non-deductible expenses

   6.6. Transactions between Related Parties and Connected Persons, and transfer pricing rules

   1. 6.6.1. Related Parties

      6.6.2. Control

      6.6.3. Connected Persons

      6.6.4. Transfer pricing

   6.7. Tax Losses

   1. 6.7.1. Tax Loss relief

      6.7.2. Tax Losses and change of ownership

      6.7.3. Transfer of Tax Losses

   6.8. Determination of Taxable Income

   6.9. Transitional rules

7. Reliefs