This official compendium provides an authoritative summary of the Federal Tax Authority (FTA) Private Clarifications regarding the UAE Corporate Tax Law issued up to May 2026. Spanning 29 separate categories, the document delivers practical, binding answers to complex compliance questions. Key areas addressed include the tax-exempt parameters for REITs and partnerships, specific permanence and disposal criteria for triggering a Permanent Establishment (PE) under the six-month rule, and structural conditions for establishing a Free Zone Qualifying Free Zone Person (QFZP). It explicitly defines the operational boundaries of Qualifying Activities (such as commodity trading, high-seas distribution, and treasury financing) while shedding clear light on core corporate issues including the Participation Exemption, asset-test related party limitations, loss transfers under beneficial ownership, and real estate transitional reliefs.
Corporate Tax - Summary of FTA Private Clarifications
Issued up to May 2026
Contents
1. Exempt Persons – Qualifying Investment Funds, Qualifying Limited Partnerships and REITs
2. Permanent Establishment
3. Unincorporated Partnerships
4. Family Foundations
5. Free Zones – Qualifying Free Zone Persons
6. Free Zones – Adequate Substance
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