Explanatory Guide On Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses

Contents

Introduction

Chapter One: General provisions

1. Article 1: Definitions

Chapter Two: Imposition of Corporate Tax and Applicable Rates

1. Article 2: Imposition of Corporate Tax

   Article 3: Corporate Tax Rate

Chapter Three: Exempt Person

1. Article 4: Exempt Person

   Article 5: Government Entity

   Article 6: Government Controlled Entity

   Article 7: Extractive Business

   Article 8: Non-Extractive Natural Resource Business

   Article 9: Qualifying Public Benefit Entity

   Article 10: Qualifying Investment Fund

Chapter Four: Taxable Person and Corporate Tax Base

1. Article 11: Taxable Person

   Article 12: Corporate Tax Base

   Article 13: State Sourced Income

   Article 14: Permanent Establishment

   Article 15: Investment Manager Exemption

   Article 16: Partners in an Unincorporated Partnership

   Article 17: Family Foundation

Chapter Five: Free Zone Person

1. Article 18: Qualifying Free Zone Person

   Article 19: Election to Be Subject to Corporate Tax

Chapter Six: Calculating Taxable Income

1. Article 20: General Rules for Determining Taxable Income

   Article 21: Small Business Relief

Chapter Seven: Exempt Income

1. Article 22: Exempt Income

   Article 23: Participation Exemption

   Article 24: Foreign Permanent Establishment Exemption

   Article 25: Non-Resident Person Operating Aircraft or Ships in International Transportation

Chapter Eight: Reliefs

1. Article 26: Transfers Within a Qualifying Group

   Article 27: Business Restructuring Relief

Chapter Nine: Deductions

1. Article 28: Deductible Expenditure

   Article 29: Interest Expenditure

   Article 30: General Interest Deduction Limitation Rule

   Article 31: Specific Interest Deduction Limitation Rule

   Article 32: Entertainment Expenditure

   Article 33: Non-Deductible Expenditure

Chapter Ten: Transactions with Related Parties and Connected Persons

1. Article 34: Arm’s Length Principle

   Article 35: Related Parties and Control

   Article 36: Payments to Connected Persons

Chapter Eleven: Tax Loss Provisions

1. Article 37: Tax Loss Relief

   Article 38: Transfer of Tax Loss

   Article 39: Limitation on Tax Losses Carried Forward

Chapter Twelve: Tax Group Provisions

1. Article 40: Tax Group

   Article 41: Date of Formation and Cessation of a Tax Group

   Article 42: Taxable Income of a Tax Group

Chapter Thirteen: Calculation of Corporate Tax Payable

1. Article 43: Currency

   Article 44: Calculation and Settlement of Corporate Tax

   Article 45: Withholding Tax

   Article 46: Withholding Tax Credit

   Article 47: Foreign Tax Credit

Chapter Fourteen: Payment and Refund of Corporate Tax

1. Article 48: Corporate Tax payment

   Article 49: Corporate Tax Refund

Chapter Fifteen: Anti-Abuse Rules

1. Article 50: General Anti-Abuse Rule

Chapter Sixteen: Tax Registration and Deregistration

1. Article 51: Tax Registration

   Article 52: Tax Deregistration

Chapter Seventeen: Tax Returns and Clarifications