One of the more difficult questions under the UAE Tax Procedures regime is whether the Federal Tax Authority (FTA) may move a matter into the...
Even where a UAE Unincorporated Partnership can qualify as an Entity, and even where it can in some cases matter within the Group perimeter, the...
Accepting that a UAE Unincorporated Partnership may qualify as an Entity does not yet resolve its Pillar Two treatment. The next question is whether that...
One of the more intriguing questions raised by the interaction between the UAE Corporate Tax regime and Pillar Two is whether a UAE unincorporated partnership...
The orthodox position in UAE tax practice is well known. A private clarification binds the Federal Tax Authority on the same facts and for the...
Co-authored by Vanshika Jain and Andrey Nikonov, PGP Tax Consultancy L.L.C Cabinet Decision No.129 of 2025, published on 10 November 2025 and effective from 14...
Federal Decree‑Law No. 28 of 2022 on Tax Procedures (the “Tax Procedures Law” or “TPL”), as amended with effect from 1 January 2026, revises the...
This case study isolates a timing tension that becomes visible only because Pillar Two is accounting anchored. A transfer price can be adjusted through a...
This case study examines whether a company resident in the United Arab Emirates may be regarded as having created a permanent establishment in another State...
At first sight, the question seems almost rhetorical: if a UAE company grants an interest-free loan to its shareholder, surely the transaction is non-arm’s length...
In “standard” compliance seasons, substance discussions are framed as design questions: where does the business truly operate, where are functions performed, and what level of...
At first sight, the question seems almost rhetorical: if a UAE company grants an interest-free loan to its shareholder, surely the transaction is non-arm’s length...
This case study considers whether the relief under Article 26 of the UAE Corporate Tax Law (the “Qualifying Group Relief” or “QGR”) can apply where...
Interpreting the OECD 2025 Update to the Commentary on Article 5 on Permanent Establishment Remote and hybrid working has forced a practical question into the...
This case study examines the application of the Principal Purpose Test (PPT) under Article 29(9) of the OECD Model Tax Convention in the context of...
The Free Zone Corporate Tax regime was drafted with a familiar instinct: where the activity is, in substance, regulated financial intermediation, the 0% rate should...
On 31 December 2025, the UAE issued Cabinet Resolution No. (209) of 2025, establishing an enhanced framework for the collection and exchange of information upon...
The UAE tax system is operationally inseparable from the EmaraTax portal. Corporate Tax and other federal tax returns are not merely “uploaded documents”. They are...
This case study examines a common transfer pricing challenge arising where different jurisdictions adopt different transfer pricing methods in relation to economically connected transactions. Such situations are...
This case study examines a timing question that naturally arises when an MNE Group is crossed the EUR 750 million “in scope” threshold early (on...
UAE administrative penalties for Voluntary Disclosure (“VD”) are often applied as though they are purely “outcome-based”: if the VD is late, a monthly 1% penalty...
The UAE hosts a significant concentration of shipping and commodity trading businesses, for which charter arrangements are a standard commercial tool. As a result, the...
The OECD’s January 2026 package on the Substance-based Tax Incentive (SBTI) Safe Harbour sits squarely in the uncomfortable intersection between two realities: Many jurisdictions use...
The Federal Tax Authority’s newly issued PMS VAT Guide No. VATGPM1 (January 2026) is notable not merely because it consolidates the Profit Margin Scheme (PMS) mechanics into...
With Federal Decree-Law No. 16 of 2025, the UAE has quietly rewritten the conditions for recovering input VAT. From 1 January 2026, new Article 54(bis)...
This case study examines the interaction between domestic classifications of a UAE transparent foundation and its treatment under the Pillar Two (GloBE) Model Rules and...
This case study examines the interaction of the Income Inclusion Rule (IIR), Qualified Domestic Minimum Top-Up Tax (QDMTT), and the Undertaxed Profits Rule (UTPR) within...
SAFEs have become a default tool for early-stage funding, but their accounting and tax life is anything but simple. Especially in the UAE, where Corporate...
On 28 August 2025, the UAE Ministry of Finance issued Ministerial Decision No. 229 of 2025 (“MD 229”) on Qualifying Activities and Excluded Activities under the Free...
On 19 March 2022, the Federal Tax Authority (FTA) issued Public Clarification VATP010, titled “Bank Interest and Dividends”. It addresses whether bank-deposit interest and dividend income...
With the issuance of Ministerial Decision (‘MD’) No. 229 of 28 August 2025, the concept of “Quoted Price” has become a cornerstone in determining whether a commodity being traded...
The jurisprudence on the interrelation between penalties for voluntary disclosure (“VD”) and late payment in UAE tax law has undergone a notable evolution since the...
Maritime Charter Parties have long addressed the risks of delay or efficiency in cargo operations through two reciprocal mechanisms: demurrage (the fee payable for exceeding agreed laytime)...
Facts A multinational enterprise (MNE) group is headquartered outside the UAE and operates through a wholly owned subsidiary (“UAECo”) in the United Arab Emirates, a...
Ministerial Decision No. 120 of 16 May 2023 introduced transitional rules for immovable property. Article 2(2) permits a taxpayer to exclude the pre-commencement portion of the gain...
The enactment of Ministerial Decision No. 229 of 28 August 2025 marks a significant evolution in the UAE Free Zone tax framework. For the first time, the...
On 19 September 2025, the UAE Federal Tax Authority (FTA) issued Public Clarification No. CTP008 on the Corporate Tax treatment of family wealth management structures. This marks...
This case study addresses the treatment of foreign exchange differences on cash and bank balances under the UAE Corporate Tax regime. The question arises from...
This Thursday, the Minister of Finance has published Ministerial Decision (MD) No. 229 of 28 August 2025, which repeals MD No. 265 of 2023 and applies retroactively from 1...
Facts Company A FZ-LLC (“Company A”) is a Qualifying Free Zone Person (“QFZP”) established in a UAE Free Zone. It is engaged in activities falling...
This case study examines the potential application of the Domestic Minimum Top-up Tax (DMTT) in the United Arab Emirates to a Group structured through entities...
Facts Company B FZ-LLC (“Company B”) is a Free Zone Person under the UAE Corporate Tax Law. It is engaged in the trading of a...
This case study addresses the application of the Authorised OECD Approach (AOA) to profit attribution for Permanent Establishments (PEs) in the United Arab Emirates. While...
The Pillar Two framework, as adopted in the UAE through the Domestic Minimum Top-Up Tax (DMTT) regime, employs a two-step mechanism to determine whether a...
This case study explores the corporate tax implications under the UAE Corporate Tax Law when a Free Zone-based developer engages in residential property projects located...
Today, on 18 July 2025, the UAE Minister of Finance published Ministerial Decision No. 173 dated 23 June 2025 titled “On Depreciation Adjustments for Investment Properties Held at...
This case study examines the transfer pricing implications of a business transfer between two related parties in the UAE where neither Qualifying Group Relief (QGR)...
The introduction of UAE Corporate Tax has transformed the compliance landscape for Free Zone and mainland companies alike. Yet, many businesses continue to face unexpected...
The OECD’s Global Anti-Base Erosion (GloBE) Rules (Pillar Two) introduce a 15% minimum effective tax rate (ETR) for large multinational enterprises (MNEs). On February 12,...
In our earlier research, we explored how the concept of “similar entities” under the UAE Corporate Tax Law could be interpreted, particularly for structures that are not...
“Navigating the FTA’s Private Clarification Process: Practical Strategies for a Favourable Outcome” — a deep dive into how UAE taxpayers can approach the Federal Tax...
This article explores how dividends and capital gains from a foreign subsidiary are treated under UAE Corporate Tax Law, on one hand, and UAE Domestic...
Facts ABC FZCO (“ABC”) is a Free Zone company licensed in the United Arab Emirates (UAE) and is engaged in the provision of both core...
On 27 May 2025, the UAE Federal Tax Authority (FTA) published the first comprehensive Corporate Tax Guide on Family Foundations No. CTGFF1, clarifying the tax treatment...
The UAE Federal Tax Authority (FTA) has issued an important clarification on VAT compliance for concerned services—i.e., services received from abroad that are subject to VAT...
This case study examines the transfer pricing implications of a Cost Contribution Arrangement (CCA) between two related parties: a landowner and a developer, each contributing assets and...
Facts An individual resident in the United States holds 100% of the shares in two legally independent companies: Indian Co incorporated and tax resident in...
In April 2025, the UAE Federal Tax Authority (FTA) released the Corporate Tax Guide on Interest Deduction Limitation Rules (CTGIDL1), providing long- awaited guidance on the application of...
On May 1, 2025, the UAE Federal Tax Authority (FTA) released Public Clarification No. CTP005, providing much-anticipated guidance on the Corporate Tax treatment of investors in Real Estate...
Facts A borrower company registered in the UAE received an interest-free loan from its foreign sister company. Both companies are wholly owned by the same...
Facts A company is a legal person registered in Dubai Multi Commodities Centre (DMCC) carries on economic activity as a UAE resident company. This Company...
In commercial practice, contracts frequently contain clauses that impose charges on debtors who fail to meet payment deadlines. These charges can appear under a variety...
Under Article 1 of the UAE Corporate Tax Law, a Qualifying Investment Fund is defined as ‘any entity whose principal activity is the issuing of investment interests to raise funds...
Yesterday, the full text of Cabinet Decision No. 35 of 27 March 2025 was released. It further clarifies and modifies the Corporate Tax obligations of non-resident persons...
Cabinet Decision No. 34, released this weekend, introduces a comprehensive new framework for Qualifying Limited Partnerships (QLPs). It applies exclusively to partnerships with legal personality, as...
Nicotine pouches are oral, non-tobacco products that deliver nicotine to the user. Typically, white and discrete, these pouches contain nicotine and other ingredients but do...
Facts An Emirati company has entered into a profit-sharing agreement (PSA) with foreign partners. The agreement relates to a trading activity in which the goods...
When a company revalues its Property, Plant, and Equipment (PPE), the following rules apply: If an asset’s carrying amount is increased, the increase shall be...
Facts A company is registered in a UAE free zone that has publicly declared its recognition as a Qualifying Free Zone for corporate tax purposes....
On 25 October 2023, the UAE’s Cabinet issued Decision No. 100.This decision repeals Cabinet Decision No. 55 of 30 May 2023, replacing earlier rules determining Qualifying...
With the Cabinet Decision No. 142 dated 31 December 2024, the UAE has proceeded introducing Domestic Minimum Top-up Tax (DMTT) rules in alignment with Pillar Two of...
Facts The holding company (Company) is registered in a qualified Free Zone in the UAE. The Company is considering the application of the 0% Corporate...
The UAE’s temporary position where only the Domestic Minimum Top-up Tax (DMTT) has already been implemented and Income Inclusion Rule (IIR) is not implemented (yet?)...
Facts A logistics company (Company) based in the UAE acts as an intermediary in arranging the transportation of goods for its clients. The transportation itself...
Facts The Company is registered in a Qualified Free Zone in the UAE to invest in securities for long-term holding. The Company holds some of...
Article 36(2)(b) of the UAE Corporate Tax Law provides that ‘a Person shall be considered a Connected Person of a Taxable Person if that Person is … A...
Facts A company registered in a Qualified Free Zone in the UAE sells software to its subsidiary, a wholly owned LLC registered in the US,...
Today, we shared our expertise on Trusts and Foundations during an almost two-hour presentation at the CFO Cafe venue. We covered both tax and legal...
The UAE’s Corporate Tax Law has introduced beneficial provisions for Family Foundations, trusts, and similar entities, offering these structures the potential to attain tax-transparent status....
On October 28, the Minister issued Decision No. 261, introducing pivotal updates under Article 5(2). This decision expands the scope of entities eligible for tax transparency,...
We are excited to share our long-awaited overview of the recently released Corporate Tax Return Guide. This comprehensive document marks a significant milestone for businesses navigating...
On 24 October 2024, the Federal Tax Authority (FTA) released essential guidance on Corporate Tax for real estate investments by individuals, addressing a complex area...
We hosted a webinar focused on the essentials of identifying and substantiating R&D activities eligible for the 0% Corporate Tax rate. I’m sharing an article...
This brief explores the dual status of offshore companies, which have dual status under corporate legislation. On the one hand, they are legal entities acting...
On October 3rd, we partnered with STI Taxand to host a joint webinar on the intricate challenges of transfer pricing within Free Zones under the...
In October 2023, the UAE retrospectively introduced tax benefits for the ownership and exploitation of intellectual property. Income from patents or software and other qualifying...
One more extract from our IP webinar last week. This group of slides addresses cases where one intellectual property item is acquired to generate another...
A company established and residing in the UAE (UAE Co.) is going to distribute applications it has developed. It is considering using the payment process...
This study is part of a wider job that we have done to answer the question of which “similar entities” can obtain Family Foundation (transparent)...
A transaction between free zone entities in the UAE qualifies for the 0% Corporate Tax rate. However, a free zone customer must be Beneficial Recipient”...
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Facts Mr Smith (Developer) is going to start an IP business in Dubai. He will develop software and sell subscriptions thereto as an application through...
The distribution of materials from a Designated Zone to a customer who processes these materials and sells the product of processing qualifies for the 0%...
This case study addresses several major issues related to the application of a 0% VAT rate to indirect exports in the UAE. First, it considers...
Here is another slide from the webinar we held last week. It demonstrates insights from one example in the Guide. There are 92 examples therein....
This Monday, we published the slides related to the definition of Ancillary Activities. In the attached slide, we delve into differentiating between Ancillary and Incidental...
The FTA’s Free Zone Persons Guide provides substantial input in obtaining clarity. However, some clarifications requires further details. Specifically, the Guide addresses how to distinguish...
This slide from the recent webinar addresses definition of a Designated Zone (DZ) for the UAE Corporate Tax (CT) purposes. Its definition was introduced by...
The facts The company is registered in Dubai Silicon Oasis. It develops software and licenses it to the customers. Generally, the software is licensed without...
In this study, we delve into VAT issues related to e-advertisements, using social media ad platforms to demonstrate the case. The focus is on applying...
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In this study, we will address two types of the transactions with debts: Acquiring a debt arising from various obligations, and then receiving the payment...
Table of contents: What are Investments Funds?Standard Taxation of the Investment Fund. Exemption for Qualifying Investment Funds. Conditions for Qualifying Investment Funds. Investment Business Condition and Diversity of...
The facts One company provides services to another company. Both are established in the UAE and have no foreign establishments. The services are actually performed...
The FTA released the Business Restructuring Guide for Corporate Tax. What is new in this Guide to use in addition to what is already known...
The facts An individual has been serving as a sole director in three companies simultaneously. All companies are registered in ADGM. The question Is his...
On November 15, 2024, a significant amendment to the UAE VAT Executive Regulation will come into effect, reshaping the way VAT is applied to the export of...
We share the presentation of Maria Nikonova, Partner at PGP Tax Consultancy, from the BRICS+ New Economy Legal Forum. She discussed the tax aspects of...
The facts The Group set up a company in the Kingdom of Saudi Arabia with a Regional Headquarter (RHQ) License. This RHQ conducts Eligible Activity...