UAE Corporate Taxchapter by chapter

Articles 2-3; Cabinet Decision 116/2022 Arts 2-3

Corporate Tax rate structure. Articles 2 and 3 of Federal Decree-Law No. 47/2022, read with Articles 2-3 of Cabinet Decision No. 116/2022, set the standard rates applied to a Taxable Person's Taxable Income each Tax Period: 0% on the portion up to and including AED 375,000, and 9% on the excess. A Qualifying Free Zone Person is instead taxed at 0% on its Qualifying Income and 9% on any Taxable Income falling outside that definition. These rate bands apply to all Taxable Persons unless a specific Free Zone, Small Business Relief, or other Cabinet-specified rate treatment displaces them for the relevant Tax Period.

Cabinet Decision 116/2022 Art 2(2)-(3)

Artificial separation of Business. Article 2(2)-(3) of Cabinet Decision No. 116/2022 provides that where two or more Persons artificially separate their Business or Business Activity, and the separation is not for a valid commercial or other non-fiscal reason reflecting economic reality, the Federal Tax Authority may treat those Persons' combined Taxable Income as a single Taxable Person's income for the purpose of applying the 0% rate threshold. The provision targets related or connected Persons who split operations mainly to obtain multiple AED 375,000 zero-rate bands rather than for genuine commercial or organisational reasons, and applies to all Taxable Persons regardless of size or sector.

Article 4(3)-(4)

Exempt Person application requirement. Article 4(3)-(4) of Federal Decree-Law No. 47/2022 provides that certain categories of Person — a Qualifying Investment Fund, a public or private pension or social security fund, a wholly-owned and controlled UAE subsidiary of an Exempt Person, and any other Person specified by Cabinet decision — are Exempt Persons only where they apply to, and are approved by, the Federal Tax Authority, in the form and manner and within the timeline the Authority prescribes. Exemption takes effect from the start of the Tax Period specified in the application, or another date determined by the Authority, rather than automatically from incorporation or formation.

Article 4(5)-(6); Article 9(3); Article 10(2); Article 17(3)

Continuing conditions for exempt status. Articles 4(5)-(6), 9(3), 10(2) and 17(3) of Federal Decree-Law No. 47/2022 provide that Exempt Person, Qualifying Public Benefit Entity, Qualifying Investment Fund and Family-Foundation-as-Unincorporated-Partnership status each depend on the relevant Person continuing to meet its specific conditions throughout the Tax Period, not just at initial approval. Where any condition ceases to be met, exempt status ends from the beginning of that Tax Period, unless a ground prescribed by the Minister — such as liquidation or a temporary, promptly-rectified failure — allows continuation. The Federal Tax Authority may request information or records at any time to verify ongoing compliance.

Articles 5-6

Government Entities and Government Controlled Entities. Articles 5 and 6 of Federal Decree-Law No. 47/2022 exempt Government Entities and Government Controlled Entities from Corporate Tax in respect of their sovereign or mandated activities, but treat any Business or Business Activity conducted under a Licence — or any activity outside the entity's Mandated Activity — as a separate, taxable Business requiring its own financial statements and independently computed Taxable Income. Transactions between that taxable activity and the entity's exempt activities are treated as Related Party transactions subject to the arm's length principle. A Government Entity or Government Controlled Entity may instead apply to the Authority to treat all its Businesses and Business Activities as a single Taxable Person.

Articles 7-8

Extractive Business and Non-Extractive Natural Resource Business exemption. Articles 7 and 8 of Federal Decree-Law No. 47/2022 exempt a Person's Extractive Business or Non-Extractive Natural Resource Business from Corporate Tax where the Person holds the requisite right, concession or Licence issued by a Local Government, is effectively subject to Emirate-level taxation on that activity, and notifies the Ministry of Finance in the agreed form. Where the Person also conducts other Business, the exemption is preserved only if that other Business does not exceed 5% of total Revenue; above that ancillary threshold, the Person must maintain separate financial statements, apportion common expenditure, and treat cross-activity dealings as Related Party transactions.

Cabinet Decision 34/2025 Articles 2-4; FTA Decision 8/2025 Articles 3-5

Qualifying Investment Fund / REIT exemption and investor adjustments. Cabinet Decision No. 34 of 2025 (replacing Cabinet Decision 81/2023) sets the conditions for an investment fund, Real Estate Investment Trust (REIT), or Qualifying Limited Partnership to be exempt from Corporate Tax as a Qualifying Investment Fund, and the corresponding Taxable Income adjustments required of their investors -- including a related-party concentration test (Article 3(2)) and, where the fund's Immovable Property Percentage exceeds 10%, an 80%-of-Immovable-Property-Income inclusion for juridical-person investors (Article 3(5)). FTA Decision No. 8 of 2025 sets the operational timelines: the fund/REIT must give affected investors the necessary calculation information within 6 months (concentration adjustment) or 9 months (Immovable Property Income adjustment) of its Financial Year end, file an annual continuing-exemption declaration within 10 months, and an affected investor must file its Tax Return and settle tax within the later of 12 months from the fund's Financial Year end or 9 months from its own Tax Period end.

Cabinet Decision 34/2025 Articles 5-6

Qualifying Limited Partnership exemption. Cabinet Decision No. 34 of 2025 Articles 5-6 let a Qualifying Limited Partnership (a UAE limited partnership formed solely for collective investment under a framework permitted on or before 1 June 2023) apply to be exempt from Corporate Tax where its principal activity is Investment Business, it derives no UAE Immovable Property income, and it is not mainly used to avoid tax; a wholly-owned subsidiary conducting only the Partnership's activities or holding assets for its benefit may apply on the same basis. The exemption application must be made in the first Tax Period the Decision applies; failure to apply, or a later failure to meet the conditions, disqualifies the Partnership from Exempt Person status for that Tax Period and the following four, with opening tax values reset from the pre-exemption closing balance sheet or acquisition cost as applicable. Investors exclude profit distributions received from an exempt Partnership from Taxable Income, but a juridical-person Taxable Person investor must include its prorated share of the Partnership's net income.

Article 11(4)(c); Cabinet Decision 35/2025

Non-Resident Person nexus via UAE Immovable Property. Cabinet Decision No. 35 of 2025 (replacing Cabinet Decision 56/2023) provides that, for Article 11(4)(c) of the Corporate Tax Law, a foreign juridical person has a nexus in the State where it derives income from UAE Immovable Property, or where its income is adjusted under the Qualifying Investment Fund/REIT rules in Cabinet Decision 34/2025 (related-party concentration, or Immovable Property Income exposure above the fund's 10% threshold). Article 3 treats an artificial transfer of rights in UAE Immovable Property lacking genuine commercial purpose as a Corporate-Tax-advantage arrangement under the Article 50 general anti-abuse rule. Article 4 requires registration for any Person with such a nexus. FTA Decision No. 8 of 2025 Articles 2, 6 and 7 set the operational timelines: registration within 12 months (Immovable Property Income nexus) or 3 months (related-party concentration nexus) of the relevant Financial Year end; a notification where the Person ceases to be a Taxable Person on this basis while remaining an investor; and deregistration within 3 months of completing 12 continuous months without any Ownership Interest in the fund.

Article 15

Investment Manager Exemption. Article 15 of Federal Decree-Law No. 47/2022 provides that a Non-Resident Person does not have a Permanent Establishment in the UAE solely because an Investment Manager conducts transactions on its behalf, provided the Investment Manager conducts a regulated investment management or brokerage business, acts in the ordinary course of that business and in an independent capacity, is remunerated at arm's length, and does not act exclusively or almost exclusively on behalf of that Non-Resident Person and its Related Parties during the relevant Tax Period. All four conditions must be satisfied concurrently for the exemption to apply.

Article 16

Unincorporated Partnership treatment. Article 16 of Federal Decree-Law No. 47/2022 treats an Unincorporated Partnership as fiscally transparent by default: it is not itself a Taxable Person, and each partner is treated as an individual Taxable Person holding a distributive share of the Partnership's assets, liabilities, income and expenditure in proportion to their ownership interest. Partners may instead apply to the Authority for the Unincorporated Partnership to be treated as a single Taxable Person under Article 16(8), in which case one partner is appointed to act on the Partnership's behalf, while all partners remain jointly and severally liable for the Corporate Tax Payable by the Partnership for the period of their membership.

Article 17

Family Foundation election. Article 17 of Federal Decree-Law No. 47/2022 allows a Family Foundation — an entity established to manage assets or funds for the benefit of identified natural persons or a public benefit purpose — to apply to be treated as an Unincorporated Partnership (fiscally transparent, look-through) for Corporate Tax purposes. Eligibility requires that the Foundation's principal activity is receiving, holding, investing, disbursing or otherwise managing assets connected with savings or investment, that it conducts no independent Business that would itself be taxable, and that its establishment does not have a tax-avoidance purpose. Approval takes effect from a Tax Period specified in the application or determined by the Authority.

Articles 11-12

Place of Effective Management (POEM) and UAE Corporate Tax residency rules. Under Article 11 of Federal Decree-Law No. 47/2022, a juridical person incorporated outside the UAE is treated as a UAE Resident Person if it is effectively managed and controlled in the UAE — determined by where the board of directors makes strategic decisions. A natural person is a Resident Person if habitually residing in the UAE or a UAE national. Article 12 covers the tax base: a Resident juridical person is taxed on worldwide Taxable Income; a Non-Resident is taxed only on UAE-sourced income attributable to a Permanent Establishment or nexus.

Articles 13-14

State Sourced Income and Permanent Establishment. Articles 13 and 14 of Federal Decree-Law No. 47/2022 define when a Non-Resident Person is taxable in the UAE. Article 13 lists State Sourced Income categories — income from goods, services, contracts, immovable property, intellectual property, interest and insurance connected to the State. Article 14 defines Permanent Establishment as a fixed or permanent place of business in the State, a dependent agent habitually exercising authority to conclude contracts, or a construction or installation project lasting more than six months, subject to exclusions for preparatory or auxiliary activities and an anti-fragmentation rule preventing artificial splitting of activities to avoid the six-month test.

Article 18; Cabinet Decision 100/2023 Arts 2-8; Ministerial Decision 229/2025 Arts 2-5

Qualifying Free Zone Person (QFZP) regime. Article 18 of Federal Decree-Law No. 47/2022, with Cabinet Decision No. 100/2023 and Ministerial Decision No. 229/2025, sets the conditions for a Free Zone Person to access the 0% Qualifying Income rate: adequate substance in a Free Zone or Designated Zone, income derived only from defined Qualifying Income categories (Free-Zone-Person transactions as Beneficial Recipient, Qualifying Activities with Non-Free Zone Persons, Qualifying Intellectual Property income, and de minimis other income capped at the lower of 5% of Revenue or AED 5,000,000), no Excluded Activities, and compliance with the arm's length and disclosure rules in Articles 34 and 55. Losing eligibility disqualifies the Person for that Tax Period and the following four.

Article 18(4)

Free Zone tax incentive period. Article 18(4) of Federal Decree-Law No. 47/2022 provides that the 0% Corporate Tax rate available to a Qualifying Free Zone Person on its Qualifying Income applies only for the remaining duration of the tax incentive period granted to that Person under the legislation of the relevant Free Zone at the time the Corporate Tax Law took effect, as such period may be extended by a Cabinet decision. In no case may the applicable incentive period, including any extension, exceed fifty years from the date the original incentive was granted, after which standard Corporate Tax rates apply to the Free Zone Person's income.

Article 19

Election to be subject to standard Corporate Tax rates. Article 19 of Federal Decree-Law No. 47/2022 allows a Free Zone Person that would otherwise qualify for the Qualifying Free Zone Person regime to instead elect to be subject to the standard Corporate Tax rates under Article 3 (0% up to AED 375,000, 9% above). The election is made in the form and manner prescribed by the Authority and takes effect from the beginning of the Tax Period in which it is made, or the following Tax Period, and — once made — displaces the 0%/9% Qualifying Income/non-Qualifying Income split that would otherwise apply under Article 18.

Cabinet Decision 100/2023 Article 7; Ministerial Decision 229/2025 Article 4

Qualifying Intellectual Property and the modified nexus approach. Article 7 of Cabinet Decision No. 100/2023 and Article 4 of Ministerial Decision No. 229/2025 permit income derived by a Qualifying Free Zone Person from Qualifying Intellectual Property to be treated as Qualifying Income, but only to the extent computed under the internationally recognised modified nexus approach — a formula linking the proportion of income benefiting from the 0% rate to the proportion of Qualifying Expenditure (broadly, in-house or unrelated-party R&D spend) within the Person's Overall Expenditure on developing the asset. The rules require records evidencing ownership or exploitation rights, the expenditure figures, and the resulting nexus ratio for each item of Qualifying Intellectual Property.

Article 20

Calculating Taxable Income. Article 20 of Federal Decree-Law No. 47/2022 establishes that Taxable Income is derived from the Taxable Person's Accounting Income, prepared under accounting standards accepted in the State, adjusted for unrealised gains and losses (unless an election is made to recognise gains and losses on a realisation basis), Exempt Income, Reliefs, Deductions, transactions with Related Parties and Connected Persons at arm's length, Tax Loss relief, and any incentive or other adjustment specified by the Cabinet for a Qualifying Business Activity. This Article is the central computational bridge between a Taxable Person's financial statements and the amount on which Corporate Tax is ultimately charged.

Article 20(1); Ministerial Decision 114/2023

Applicable Accounting Standards. Ministerial Decision No. 114/2023, made under Article 20(1) of Federal Decree-Law No. 47/2022, requires a Taxable Person to prepare Financial Statements under IFRS. A Taxable Person whose Revenue does not exceed AED 50,000,000 may instead apply IFRS for SMEs. A Taxable Person whose Revenue does not exceed AED 3,000,000 may prepare Financial Statements on a Cash Basis of Accounting (recognising income/expenditure on cash receipt/payment); a Taxable Person above that threshold may still apply to the Authority to use the Cash Basis in exceptional circumstances. The Decision also clarifies that a Tax Group's Article 42(11) consolidated Financial Statements mean the aggregation of standalone Parent/Subsidiary statements with intra-group transactions eliminated.

Article 20(6)

Change of accounting basis. Article 20(6) of Federal Decree-Law No. 47/2022 permits a Taxable Person that prepares its financial statements on a cash basis of accounting to change to the accrual basis, but only with the prior approval of the Federal Tax Authority, obtained by application specifying the Tax Period from which the change is to take effect. This provision governs the transition between the two recognised accounting bases used to determine Accounting Income under Article 20(1), and prevents a Taxable Person from switching methods unilaterally or retroactively without the Authority's consent.

Article 21; Ministerial Decision 73/2023

Small Business Relief. Article 21 of Federal Decree-Law No. 47/2022, with Ministerial Decision No. 73/2023, allows a Resident Person to elect to be treated as having no Taxable Income for a Tax Period where its Revenue does not exceed AED 3,000,000 in that Tax Period and in all previous Tax Periods, available only for Tax Periods ending on or before 31 December 2026. The relief is not available to a Constituent Company of a Multinational Enterprise Group or to a Qualifying Free Zone Person. Electing disapplies Exempt Income, Reliefs, Deductions, Tax Loss relief and Article 55 disclosure for that Tax Period, and Tax Losses or Net Interest Expenditure arising in an election year cannot be carried forward.

Article 23; Ministerial Decision 116/2023

Participation Exemption -- detailed conditions. Ministerial Decision No. 116/2023 elaborates the Article 23 Participation Exemption test beyond the headline 5%/9%/12-month conditions already captured generically in this register: an ownership interest qualifying via the AED 4,000,000 minimum acquisition cost alternative (Article 8) must aggregate capitalised acquisition/transfer expenditure and subsequent capital movements, and is lost if the threshold is not met for an uninterrupted 12-month period; a Participation relied on as a qualifying holding company (Article 7) must be directed and managed, and meet local filing obligations, in the other jurisdiction, have adequate offshore personnel/premises for its holding activity, and conduct no more than incidental/ancillary activities; and on liquidation (Article 12), the Taxable Person must calculate a liquidation gain or loss as the acquisition cost less the fair value of liquidation proceeds, adjusted for transferred Tax Losses, previously exempt Dividends, and untaxed intra-group asset transfers.

Article 24

Foreign Permanent Establishment exemption. Article 24 of Federal Decree-Law No. 47/2022 allows a Resident Person to elect to exempt from Taxable Income the income and associated expenditure of its Foreign Permanent Establishments, but only where each such Foreign Permanent Establishment is subject to Corporate Tax or a comparable tax of at least 9% in the foreign jurisdiction in which it is situated. The election must be applied consistently to all of the Resident Person's Foreign Permanent Establishments — it cannot be made selectively on a jurisdiction-by-jurisdiction basis — and, once made, any Foreign Tax Credit otherwise available in respect of the exempted Foreign Permanent Establishment income is forfeited.

Article 25

International transportation income exemption. Article 25 of Federal Decree-Law No. 47/2022 exempts income derived by a Non-Resident Person from operating aircraft or ships in international transportation — including the transport of passengers, livestock, mail, parcels, merchandise or goods, and the leasing or chartering of aircraft or ships used in international transportation, or associated containers — from UAE Corporate Tax. The exemption is conditional on reciprocity: it applies only where a UAE Resident Person conducting equivalent international transportation activities would be exempt from, or not subject to, a comparable tax on that income in the Non-Resident Person's own jurisdiction.

Articles 22-23

Participation Exemption. Articles 22 and 23 of Federal Decree-Law No. 47/2022 exclude dividends, profit distributions, and gains or losses on disposal of an ownership interest in a Participation from Taxable Income, provided the Taxable Person holds (or intends to hold) at least a 5% ownership interest for an uninterrupted 12-month period, the Participation is subject to Corporate Tax or a comparable tax of at least 9% in its jurisdiction, the Taxable Person is entitled to at least 5% of distributable profits and liquidation proceeds, and no more than 50% of the Participation's assets consist of ownership interests that would not themselves qualify. The exemption is clawed back if ownership falls below 5% within the 12-month period.

Article 26

Qualifying Group relief. Article 26 of Federal Decree-Law No. 47/2022 allows assets or liabilities to be transferred between members of a Qualifying Group — companies under at least 75% common direct or indirect ownership, none of which is an Exempt Person or a Qualifying Free Zone Person, sharing a common Financial Year and accounting standards — at net book value, so that no gain or loss arises for Corporate Tax purposes on the transfer. The relief is subject to a two-year claw-back: if the asset or liability is transferred outside the Qualifying Group, or the transferor and transferee cease to be members of the same Qualifying Group, within two years, the transfer is restated at Market Value.

Article 27

Business Restructuring Relief. Article 27 of Federal Decree-Law No. 47/2022 allows a Taxable Person to transfer an entire Business, or an independent part of a Business, in exchange for shares or other ownership interests, without recognising a gain or loss, provided the conditions in Article 27(2) are met — including that both transferor and transferee are Resident Persons, neither is Exempt or a Qualifying Free Zone Person, they share a common Financial Year, and the restructuring has a valid commercial or non-fiscal reason. Unutilised Tax Losses of the transferor carry forward to the transferee (apportioned for a partial-Business transfer), subject to a two-year claw-back if the shares received, or the transferred Business, are subsequently disposed of.

Article 28

General deductibility test. Article 28 of Federal Decree-Law No. 47/2022 provides that expenditure is deductible in computing Taxable Income only to the extent it is incurred wholly and exclusively for the purposes of the Taxable Person's Business, and only in the Tax Period in which it is incurred. Expenditure incurred for both business and non-business (or Exempt Income) purposes must be apportioned on a fair and reasonable basis, with only the business-related portion deductible. Expenditure that is not incurred for Business purposes, that relates to deriving Exempt Income, or that constitutes a loss unconnected with or not arising out of the Business, is not deductible.

Article 30; Ministerial Decision 126/2023

General Interest Deduction Limitation Rule. Article 30 of Federal Decree-Law No. 47/2022, with Ministerial Decision No. 126/2023, caps the deductible Net Interest Expenditure of a Taxable Person at 30% of its adjusted EBITDA for the Tax Period, calculated in accordance with Ministerial Decision No. 126/2023 Article 9 (including transitional treatment for debt existing before 9 December 2022 and a carve-out for Qualifying Infrastructure Projects), unless Net Interest Expenditure for the period does not exceed the AED 12,000,000 de minimis threshold. Disallowed Net Interest Expenditure may be carried forward and deducted in any of the following ten Tax Periods. Banks, Insurance Providers and natural persons conducting Business are excluded from the rule.

Article 31

Specific Interest Deduction Limitation Rule. Article 31 of Federal Decree-Law No. 47/2022 restricts the deduction of Interest expenditure on a loan obtained, directly or indirectly, from a Related Party where that loan funds a dividend or profit distribution, a capital reduction, redemption, repurchase or return of capital, a capital contribution, or the acquisition of an ownership interest in a Person that is or becomes a Related Party following the acquisition. The Interest remains deductible only if the Taxable Person can demonstrate the main purpose of obtaining the loan was not to gain a Corporate Tax advantage, or that the Related Party lender is subject to tax on the Interest income at a rate of at least 9%.

Article 32

Entertainment expenditure cap. Article 32 of Federal Decree-Law No. 47/2022 limits the deduction of entertainment, amusement and recreation expenditure incurred for the purpose of entertaining customers, shareholders, suppliers or other business partners — including expenditure on meals, accommodation, transportation, admission fees, and facilities and equipment used in connection with such entertainment — to 50% of the amount actually incurred. The remaining 50% is treated as non-deductible regardless of the extent to which the expenditure would otherwise satisfy the wholly-and-exclusively test in Article 28, reflecting a policy judgment that entertainment expenditure carries an inherent element of personal or non-business benefit.

Article 33

Non-deductible expenditure. Article 33 of Federal Decree-Law No. 47/2022 lists categories of expenditure that are never deductible in computing Taxable Income regardless of their connection to the Business: donations, grants and gifts made to an entity that is not a Qualifying Public Benefit Entity; fines and penalties, other than amounts awarded as compensation for damages or breach of contract; bribes and other illicit payments; dividends, profit distributions and similar benefits to owners; amounts withdrawn from a Business by a natural person or Unincorporated Partnership partner; Corporate Tax itself; recoverable input Value Added Tax; and tax on income imposed outside the UAE.

Article 34

Arm's Length Principle and Transfer Pricing. Article 34 of Federal Decree-Law No. 47/2022 requires transactions and arrangements between a Taxable Person and its Related Parties, and with its Connected Persons, to be priced as if they had been made between independent parties, applying the arm's length principle. The Taxable Person must select and apply the most appropriate transfer pricing method — comparable uncontrolled price, resale price, cost-plus, transactional net margin, transactional profit split, or another method it can justify is more appropriate — having regard to the transaction's contractual terms, characteristics, economic circumstances, and the functions, assets and risks of the parties involved, and adjust its Taxable Income where results fall outside the arm's length range.

Article 35

Related Parties and Control. Article 35 of Federal Decree-Law No. 47/2022 defines who counts as a Related Party for transfer pricing and other purposes: natural persons related within the fourth degree of kinship or affiliation (including spouses); a natural person and a juridical person where the natural person, alone or with Related Parties, owns at least 50% of, or Controls, the juridical person; two or more juridical persons under common 50%-or-greater ownership or Control; a Person and its Permanent Establishment; partners in the same Unincorporated Partnership; and a trustee, founder, settlor or beneficiary of a trust or foundation and its Related Parties. Control includes the ability to influence, directly or indirectly, significant decisions of another Person.

Article 36

Connected Persons and the Market Value test. Article 36 of Federal Decree-Law No. 47/2022 restricts the deduction of payments or benefits provided by a Taxable Person to a Connected Person — an owner of the Taxable Person, a director or officer of the Taxable Person, or a Related Party of either — to the extent the payment or benefit reflects the Market Value of the service, benefit or asset provided and is incurred wholly and exclusively for the purposes of the Taxable Person's Business. The restriction does not apply where the Taxable Person's shares are traded on a Recognised Stock Exchange, or where the Taxable Person is subject to the regulatory oversight of a competent authority in the State.

Article 55(1)-(2); Ministerial Decision 97/2023

Master File and Local File thresholds. Article 55(1)-(2) of Federal Decree-Law No. 47/2022, with Ministerial Decision No. 97/2023, requires a Taxable Person to prepare and maintain a master file and a local file where it is a Constituent Company of a Multinational Enterprise Group with total consolidated group Revenue of AED 3,150,000,000 or more in the relevant Tax Period, or where the Taxable Person's own Revenue is AED 200,000,000 or more. Ministerial Decision No. 97/2023 Article 2 scopes the local file to transactions and arrangements with Non-Resident Persons, Exempt Persons, Resident Persons that have elected Small Business Relief, and Resident Persons taxed at a different Corporate Tax rate.

Article 55(3)-(4)

Transfer pricing documentation on request. Article 55(3)-(4) of Federal Decree-Law No. 47/2022 requires a Taxable Person, on request by the Federal Tax Authority, to submit its master file and local file (where required) and any other information necessary to support the arm's length nature of its transactions or arrangements with Related Parties and Connected Persons. The information must be provided within 30 days of the Authority's request, or such longer period as the Authority may direct, distinguishing this from the standing obligation in Article 55(1)-(2) to prepare and maintain the documentation, which applies irrespective of whether the Authority has yet made a request.

Article 37

Tax Loss relief. Article 37 of Federal Decree-Law No. 47/2022 allows a Tax Loss incurred in one Tax Period to be carried forward and offset against the Taxable Income of a subsequent Tax Period, up to a maximum of 75% (or such other percentage as the Cabinet may prescribe) of that subsequent period's Taxable Income before the relief is applied. Losses incurred before the commencement of Corporate Tax, before the Person became a Taxable Person, or that relate to an exempt or otherwise disregarded activity, may not be relieved. Carried-forward Tax Losses of the Taxable Person itself must be utilised before any Tax Loss transferred in from another Person under Article 38.

Article 38

Transfer of Tax Losses. Article 38 of Federal Decree-Law No. 47/2022 permits a Taxable Person to transfer all or part of its Tax Loss to another Resident juridical Taxable Person, where the two are under common ownership of at least 75%, maintained from the start of the Tax Period in which the loss was incurred to the start of the Tax Period in which it is offset; neither is an Exempt Person or a Qualifying Free Zone Person; and both share a common Financial Year and prepare financial statements using the same accounting standards. The amount transferable is subject to the same 75%-of-Taxable-Income cap that applies to Tax Loss relief generally under Article 37(2).

Article 39

Continuity of business test for carried-forward losses. Article 39 of Federal Decree-Law No. 47/2022 restricts a Taxable Person's ability to carry forward and utilise Tax Losses following a change of more than 50% in its ownership. Unless its shares are listed on a Recognised Stock Exchange, the Taxable Person must show that, following the ownership change, it continues the same or a similar Business or Business Activity as before the change, using substantially the same assets, without a material change to its core identity or operations. Where the continuity condition is not met, Tax Losses incurred before the ownership change are forfeited and cannot be carried forward.

Article 40(1)-(3),(9); Ministerial Decision 301/2024 Arts 2-3,5

Tax Group formation. Article 40(1)-(3) and (9) of Federal Decree-Law No. 47/2022, with Ministerial Decision No. 301/2024 Articles 2-3 and 5, allow two or more Resident Persons to apply to the Federal Tax Authority to be treated as a single Taxable Person — a Tax Group — where a Parent Company holds at least 95% of the share capital, voting rights, and entitlement to profits and net assets of each Subsidiary, all members are Resident Persons not treated as resident elsewhere under an international agreement, none is an Exempt Person or Qualifying Free Zone Person, and all share a common Financial Year and accounting standards. A new Subsidiary may join an existing Tax Group on the same conditions.

Article 40(5)-(8),(13)

Parent Company obligations and joint liability. Article 40(5)-(8) and (13) of Federal Decree-Law No. 47/2022 make the Parent Company of a Tax Group responsible for all Corporate Tax compliance on the Group's behalf — payment, registration, deregistration and Tax Return filing. The Parent Company and each Subsidiary are jointly and severally liable for the Corporate Tax Payable by the Tax Group for the Tax Periods during which they were members, unless the Federal Tax Authority approves limiting liability to specific members. The Authority retains discretion, based on available information, to dissolve a Tax Group or to replace its Parent Company where it considers this appropriate.

Article 40(10)-(12); Ministerial Decision 301/2024 Arts 5,10

Leaving or ceasing a Tax Group. Article 40(10)-(12) of Federal Decree-Law No. 47/2022, with Ministerial Decision No. 301/2024 Articles 5 and 10, governs applications for a Subsidiary to leave a Tax Group, for a Tax Group to cease to exist, or for the Parent Company to be replaced without discontinuing the Tax Group. Such applications must be made to the Federal Tax Authority before the end of the relevant Tax Period, and a Parent Company replacement is permitted only where the succession and business-transfer conditions in Ministerial Decision No. 301/2024 are satisfied, ensuring the replacement Parent Company continues to hold the requisite 95% ownership interest across the Group's Subsidiaries.

Article 42; Ministerial Decision 301/2024 Arts 4,6-8,11,13; Ministerial Decision 126/2023 Art 12

Tax Group consolidation. Article 42 of Federal Decree-Law No. 47/2022, with the related provisions of Ministerial Decision No. 301/2024 and Ministerial Decision No. 126/2023 Article 12, requires the Parent Company to consolidate the financial results, assets and liabilities of each Subsidiary and eliminate transactions between Group members, other than deductible pre-Grouping losses not yet reversed. The consolidation applies specific ordering rules for utilising each member's pre-Grouping Tax Losses and pre-Grouping Net Interest Expenditure, requires member-level Taxable Income attribution consistent with Article 34's arm's length principle, and triggers additional Article 55 disclosure where pre-Grouping amounts are used or a new member joins with existing Group losses.

Ministerial Decision 301/2024 Article 12

Notification of Tax Group changes. Article 12 of Ministerial Decision No. 301/2024 requires the Parent Company to notify the Federal Tax Authority within 20 business days where a Subsidiary leaves the Tax Group, or the Tax Group ceases to exist, as a result of no longer satisfying the ownership, residency, or other conditions for Tax Group status set out in Article 40 of Federal Decree-Law No. 47/2022. This is a standalone, time-bound notification obligation distinct from the underlying application processes in Article 40(10)-(12), triggered automatically once the Group or a member no longer meets the qualifying conditions, regardless of whether an application has already been made.

Ministerial Decision 301/2024 Article 13

Standalone financial statements on exit. Article 13 of Ministerial Decision No. 301/2024 requires a Subsidiary that leaves a Tax Group, or the former Parent Company where the Tax Group ceases to exist, to prepare standalone Financial Statements applying the same accounting basis and elections that the Tax Group applied while the Person was a member. The opening asset and liability values in those standalone Financial Statements must be the values recorded for those assets and liabilities in the Tax Group's own consolidated Financial Statements immediately before the Person's exit, preserving continuity of tax basis rather than allowing a step-up or step-down in value on separation.

Article 43

Currency of Corporate Tax amounts. Article 43 of Federal Decree-Law No. 47/2022 requires that all amounts taken into account for Corporate Tax purposes — including Taxable Income, Deductions, Reliefs, credits and Corporate Tax Payable — be quantified in United Arab Emirates dirham. Where an amount is denominated or incurred in a foreign currency, it must be converted to dirham applying the exchange rate published by the Central Bank of the United Arab Emirates, subject to any conditions the Federal Tax Authority may prescribe as to timing, source rate, or averaging methodology for the conversion.

Article 44

Order of settling Corporate Tax Payable. Article 44 of Federal Decree-Law No. 47/2022 sets the sequence in which a Taxable Person's Corporate Tax Payable for a Tax Period must be settled: first against any available Withholding Tax Credit, then against any available Foreign Tax Credit, then against any other credit or relief specified by the Cabinet, with any amount remaining after applying those credits settled in cash under Article 48. The provision ensures credits are applied consistently across all Taxable Persons in the same order, rather than at the Taxable Person's discretion, before a residual cash payment obligation arises.

Article 47

Foreign Tax Credit. Article 47 of Federal Decree-Law No. 47/2022 allows a Taxable Person to credit foreign tax paid on income that is also subject to UAE Corporate Tax against its Corporate Tax due, up to the amount of Corporate Tax payable on that same income. The credit is non-refundable and cannot be carried forward to a later Tax Period or carried back to an earlier one if it exceeds the Corporate Tax due on the relevant income for that period. The Taxable Person must maintain all records necessary to substantiate the amount of foreign tax paid and its connection to the income concerned.

Articles 45-46

Withholding Tax and Withholding Tax Credit. Articles 45 and 46 of Federal Decree-Law No. 47/2022 empower the Cabinet to specify categories of State Sourced Income paid to a Non-Resident Person that are subject to Withholding Tax at a Cabinet-prescribed rate (currently 0%), to be withheld and remitted by the payer. Article 46 grants the recipient a Withholding Tax Credit against its Corporate Tax Payable equal to the tax withheld, capped at the lower of the tax actually withheld or the Corporate Tax due for the period, with any excess credit refundable to the Taxable Person on application.

Article 48

Corporate Tax payment deadline. Article 48 of Federal Decree-Law No. 47/2022 requires a Taxable Person to settle its Corporate Tax Payable for a Tax Period within nine months from the end of that Tax Period, or by such other date as the Federal Tax Authority determines. This nine-month payment deadline runs in parallel with the nine-month Tax Return filing deadline in Article 53, meaning payment and filing are generally due at the same time, though the Authority retains discretion to specify a different payment date in particular circumstances.

Article 49

Corporate Tax refund. Article 49 of Federal Decree-Law No. 47/2022 entitles a Taxable Person to apply for a refund of Corporate Tax under the mechanism set out in the Tax Procedures Law, in circumstances including where the Taxable Person's available Withholding Tax Credit exceeds its Corporate Tax Payable for the period, or where the Federal Tax Authority is otherwise satisfied that Corporate Tax has been paid in excess of the amount properly due. The refund process and any conditions attaching to it are governed by the Tax Procedures Law rather than by the Corporate Tax Law itself.

Article 50

General Anti-Abuse Rule. Article 50 of Federal Decree-Law No. 47/2022 empowers the Federal Tax Authority to counteract a Corporate Tax advantage obtained from a transaction or arrangement, or part of one, that was entered into or carried out with the main purpose, or one of the main purposes, of obtaining that advantage in a manner inconsistent with the intention of the Corporate Tax Law, and that is not entered into for valid commercial or other non-fiscal reasons reflecting economic reality. Where the rule applies, the Authority may make a counteracting adjustment to the Taxable Person's Corporate Tax position, including by disregarding or recharacterising the transaction or arrangement.

Article 51(1); Ministerial Decision 43/2023; FTA Decision 3/2024

Corporate Tax Registration deadlines. Article 51(1) of Federal Decree-Law No. 47/2022, with Ministerial Decision No. 43/2023 and FTA Decision No. 3/2024, requires every Taxable Person to register for Corporate Tax and obtain a Tax Registration Number within deadlines set by reference to the type of Person: a licence-issuance-month schedule for pre-existing Resident juridical persons; three months from incorporation (or from Financial Year end for foreign-incorporated but State-managed persons) for newly formed Resident juridical persons; and specified periods from Permanent Establishment existence, nexus establishment, or Turnover-threshold breach for Non-Resident juridical persons and natural persons. Ministerial Decision No. 43/2023 exempts Government Entities, Government Controlled Entities, qualifying Extractive/Non-Extractive Resource Businesses, and certain Non-Resident Persons from registration.

Article 51(2)

Registration for exempt-category Persons. Article 51(2) of Federal Decree-Law No. 47/2022 empowers the Federal Tax Authority to require certain Exempt Persons — those falling within Article 4 paragraphs (e) to (i), such as a Qualifying Investment Fund, pension or social security fund, wholly-owned subsidiary of an Exempt Person, or Cabinet-specified Person — and Unincorporated Partnerships making an Article 53(6) declaration, to register for Corporate Tax and obtain a Tax Registration Number, notwithstanding that such Persons are not themselves subject to tax on their income. This registration requirement exists to allow the Authority to track and administer exempt-category Persons within the Corporate Tax system.

Article 52; FTA Decision 6/2023

Corporate Tax Deregistration. Article 52 of Federal Decree-Law No. 47/2022, with FTA Decision No. 6/2023, requires a Taxable Person to apply for Tax Deregistration within three months of ceasing its Business or Business Activity, whether by dissolution, liquidation or otherwise, applicable to both natural and juridical Persons. Deregistration cannot be approved until the Taxable Person has settled all Corporate Tax and Administrative Penalties due and filed all outstanding Tax Returns, including a final Tax Return covering the period up to the date of cessation, ensuring the Authority closes out the Taxable Person's full compliance history before removing it from the Corporate Tax register.

Article 53(1)-(3)

Tax Return filing. Article 53(1)-(3) of Federal Decree-Law No. 47/2022 requires a Taxable Person to file a Tax Return with the Federal Tax Authority within nine months of the end of the relevant Tax Period, or by such other date as the Authority directs. The Tax Return must be filed in the prescribed form and include the Tax Period covered, identifying details of the Taxable Person, the date of submission, the accounting basis used in the financial statements, the Taxable Income for the period, any Tax Loss relief claimed or transferred, tax credits claimed, and the resulting Corporate Tax Payable, together with any further information the Authority reasonably requires.

Article 53(5)-(7)

Declarations and Tax Group returns. Article 53(5)-(7) of Federal Decree-Law No. 47/2022 requires certain Persons to submit declarations rather than, or in addition to, a standard Tax Return: an exempt-category Person falling within Article 4 paragraphs (e) to (i) must submit an Article 4 declaration where directed by the Authority, and the authorised partner of an Unincorporated Partnership must submit a declaration on the Partnership's behalf. Where Persons form a Tax Group under Article 40, the Parent Company is responsible for filing a single Tax Return covering the whole Tax Group, rather than each member filing separately.

Article 54; Ministerial Decision 84/2025

Financial statements and audit requirements. Article 54 of Federal Decree-Law No. 47/2022, with Ministerial Decision No. 84/2025, requires a Taxable Person to submit its financial statements to the Federal Tax Authority on request. Audited financial statements are mandatory for a standalone Taxable Person, other than a member of a Tax Group, whose Revenue exceeds AED 50,000,000 in the relevant Tax Period, and for every Qualifying Free Zone Person regardless of Revenue; a Tax Group must instead prepare audited special-purpose financial statements at the consolidated level. Partners in an Unincorporated Partnership must provide both partnership-level financial statements and their own distributive-share statements on request.

Article 56

Record retention. Article 56 of Federal Decree-Law No. 47/2022 requires a Taxable Person to keep all records and documents that support the information contained in a Tax Return, or any other document required under the Corporate Tax Law or Tax Procedures Law, for seven years following the end of the Tax Period to which they relate. An Exempt Person is subject to a parallel obligation to maintain records sufficient for the Federal Tax Authority to readily ascertain that the Person's exempt status was, and continues to be, properly held throughout the relevant period, even though it files no Taxable Income computation.

Article 58; FTA Decision 5/2023

Change of Tax Period. Article 58 of Federal Decree-Law No. 47/2022, with FTA Decision No. 5/2023, allows a Taxable Person to apply to the Federal Tax Authority to change its Tax Period — for example on liquidation, to align its Financial Year with a Tax Group member, head office, subsidiary, parent or ultimate parent, or for another valid commercial, economic or legal reason. The application must be made before six months have elapsed from the end of the original Tax Period and before the Tax Return for that period is filed. Any extended Tax Period may not exceed eighteen months, and any shortened period must fall between six and twelve months.

Article 59

Clarifications and Advance Pricing Agreements. Article 59 of Federal Decree-Law No. 47/2022 allows a Person to apply to the Federal Tax Authority for a clarification on the application of the Corporate Tax Law to a specific transaction or proposed transaction, or for an advance pricing agreement covering the transfer pricing treatment of one or more future transactions or arrangements with Related Parties. Applications must be made in the form and manner the Authority prescribes, giving a Taxable Person a way to obtain certainty on a specific Corporate Tax question or pricing methodology in advance of filing a Tax Return, rather than resolving the position only after the event through a Tax Audit or dispute.

Article 60; Cabinet Decision 75/2023 (as amended by Cabinet Decision 10/2024) Penalty Table

Administrative Penalties. Article 60 of Federal Decree-Law No. 47/2022 empowers the Cabinet to prescribe Administrative Penalties for violations of the Corporate Tax Law, set out in the penalty table in Cabinet Decision No. 75/2023 as amended by Cabinet Decision No. 10/2024. Penalties include AED 10,000 (AED 20,000 for a repeat violation within 24 months) for record-keeping failures, AED 1,000 per month (capped at AED 10,000) for late deregistration, 14% per annum applied monthly to unsettled tax for late payment, AED 500 per month for the first twelve months then AED 1,000 per month for a late Tax Return, and AED 10,000 for a late Tax Registration application, among other specified violations.

Article 61

Transitional rules — opening balance sheet. Article 61 of Federal Decree-Law No. 47/2022 requires a Taxable Person, for its first Tax Period under the Corporate Tax Law, to prepare an opening balance sheet for Corporate Tax purposes derived from the closing balance sheet prepared for financial reporting purposes as at the last day of the immediately preceding Financial Year. The arm's length principle in Article 34 applies to the assets, liabilities and other opening positions carried into that opening balance sheet, subject to any conditions or adjustments the Minister may prescribe and any transitional measures the Cabinet may separately issue.

Article 61; Ministerial Decision 120/2023

Transitional adjustments for pre-existing assets/liabilities. Ministerial Decision No. 120/2023, made under Article 20(2)(i) and Article 61(1) of Federal Decree-Law No. 47/2022, lets a Taxable Person elect to exclude, on eventual disposal, the portion of gain (or gain/loss for financial instruments) on Immovable Property, Intangible Assets, and Financial Assets/Liabilities that accrued before the Taxable Person's first Tax Period, where those assets/liabilities were held at historical cost before that first Tax Period. The excluded amount is calculated either by Market Value at the start of the first Tax Period (Immovable Property only) or by day-apportioning the pre-existing gain over the total ownership period. The election is made per asset class upon submission of the first Tax Return and is irrevocable outside exceptional, Authority-approved circumstances; for Intangible Assets, the pre-Tax-Period ownership period used in the calculation cannot exceed 10 years without Authority approval. Article 5 extends ownership-period counting to assets transferred within a Qualifying Group or Tax Group.

Cabinet Decision 85/2022 Articles 3-6

Tax Residency Certificate. Articles 3 to 6 of Cabinet Decision No. 85/2022 set out the criteria the Federal Tax Authority applies, and the certificate it issues, to confirm UAE tax residency for domestic or international-treaty purposes. A juridical person is UAE tax resident if incorporated, formed or otherwise recognised under UAE legislation; a natural person is UAE tax resident under either a 183-day physical presence test in a 12-month period, or a 90-day-plus test combined with a Permanent Place of Residence, UAE nationality, or State employment or Business. Where an International Agreement prescribes different residency conditions for treaty purposes, those conditions apply instead, using the Ministry-prescribed treaty certificate form.

Ministerial Decision 133/2023 Arts 5, 8

Unutilised tax losses may be transferred if the Transferee continues a similar business and must be reported for tax if shares are sold outside the Qualifying Group.

Ministerial Decision 133/2023 Arts 2, 4, 6

The Transferor must elect to apply specific tax relief, with restrictions on additional considerations received during the transaction.

Ministerial Decision 133/2023 Art 9; CT Law Art 56

Both Transferor and Transferee must keep business transfer records for 7 years after the relevant tax period ends.

Article 56(1)-ret

Taxpayers must retain records and documents supporting their Tax Return information, or enabling taxable income to be readily ascertained, for seven years from the end of the relevant Tax Period.

Article 56(2)-ret

Exempt Persons must retain records enabling their exempt status to be readily ascertained for seven years from the end of the relevant tax period.