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A fixed or permanent place used only for storing, displaying, delivery of goods, or for keeping a stock of goods for processing by another person. | What would not be considered a Permanent Establishment in the UAE? |
When its general purpose is identical to the general purpose of the foreign enterprise. | When would a fixed or permanent place in the UAE be considered a preparatory or auxiliary activity? |
Clause 4. | Which clause disallows Clause 3 under certain conditions? |
When the same Non-Resident Person or a Related Party carries on a Business or Business Activity in the UAE through a separate Permanent Establishment that, when combined, would form a cohesive Business not satisfying the requirements of Clause 3. | When does Clause 4 disapply Clause 3? |
The State's Territory includes the lands, territorial sea, and airspace above it. | What is the definition of 'State's Territory'? |
Natural resources include water, oil, gas, coal, naturally formed minerals, and other non-renewable, non-living resources that may be extracted from the State's Territory. | What are considered natural resources? |
Extractive business refers to the business or activity of exploring, extracting, removing, or otherwise producing and exploiting the natural resources of the State or any interest therein, as determined by the Minister. | What is meant by 'extractive business'? |
A non-extractive natural resource business refers to the business or activity of separating, treating, refining, processing, storing, transporting, marketing, or distributing the natural resources of the State. | What is a non-extractive natural resource business? |
A qualifying public benefit entity is any entity that meets the conditions set out in Article 9. | What is a qualifying public benefit entity? |
The Minister determines the definition of extractive business. | Who determines the definition of extractive business? |
The Minister determines the natural resources of the State or any interest therein that are associated with the extractive business. | What does the Minister determine in relation to extractive business? |
Non-extractive natural resource business includes separating, treating, refining, processing, storing, transporting, marketing, and distributing the natural resources of the State. | What activities are included in non-extractive natural resource business? |
The term 'Business' encompasses both extractive and non-extractive natural resource activities. | What does the term 'Business' encompass? |
A qualifying public benefit entity is defined by meeting the conditions set out in Article 9. | How is a qualifying public benefit entity defined? |
No, the definition of 'State's Territory' includes lands, territorial sea, and airspace above it. | Is the definition of 'State's Territory' limited to just lands? |
The purpose of regulating the entity is specified in a decision issued by the Cabinet at the suggestion of the Minister. | What is the purpose of regulating the entity? |
The category of natural resources includes water, oil, gas, coal, naturally formed minerals, and other non-renewable, non-living resources. | What is included in the category of natural resources? |
The term 'extracting' in extractive business refers to the process of removing or obtaining natural resources from the State's territory. | What does the term 'extracting' refer to in extractive business? |
The activities involved in non-extractive natural resource business include separating, treating, refining, processing, storing, transporting, marketing, and distributing natural resources. | What are the activities involved in non-extractive natural resource business? |
The payment or benefit must correspond with the Market Value of the service, benefit, or otherwise provided by the Connected Person and be incurred wholly and exclusively for the purposes of the Taxable Person's Business. | What is the requirement for a payment or benefit provided by a Taxable Person to its Connected Person to be deductible? |
A Person is considered a Connected Person of a Taxable Person if they are an owner of the Taxable Person, a director or officer of the Taxable Person, or a Related Party of any of the Persons mentioned. | How is a Person considered a Connected Person of a Taxable Person? |
Being a Connected Person determines whether a payment or benefit provided by a Taxable Person is deductible or not. | What is the significance of being a Connected Person? |
A 'Connected Person' refers to someone who is an owner, director, officer, or Related Party of a Taxable Person. | What is the definition of 'Connected Person'? |
Yes, for the payment or benefit to be deductible, it must correspond with the Market Value of the service, benefit, or otherwise provided by the Connected Person. | Is there a requirement for the payment or benefit to correspond with the Market Value? |
No, the payment or benefit must be incurred wholly and exclusively for the purposes of the Taxable Person's Business in order to be deductible. | Can a payment or benefit provided by a Taxable Person to its Connected Person be deductible even if it is not incurred wholly and exclusively for the purposes of the Taxable Person's Business? |
The purpose of Article 36 is to regulate payments to Connected Persons and determine the conditions under which such payments are deductible. | What is the purpose of Article 36 of the Decree-Law? |
A payment or benefit provided by a Taxable Person to its Connected Person is deductible if and to the extent it corresponds with the Market Value of the service, benefit, or otherwise provided by the Connected Person and is incurred wholly & exclusively for the purposes of the Taxable Person's Business. | What is the general rule for deductibility of payments or benefits to Connected Persons? |
Yes, there may be exceptions as specified in Article28 of the Decree-Law. | Are there any exceptions to the deductibility of payments or benefits to Connected Persons? |
The Market Value is determined based on the value of the service, benefit, or otherwise provided by the Connected Person. | Who determines the Market Value of the service, benefit, or otherwise provided by the Connected Person? |
Being a director or officer of the Taxable Person is one of the factors that lead to a Person being considered a Connected Person. | What is the role of being a director or officer of the Taxable Person in determining Connected Person status? |
Yes, a Person can be a Connected Person if they are a Related Party of any of the owners, directors, or officers of the Taxable Person. | Can a Person be a Connected Person of a Taxable Person without being an owner, director, or officer? |
The purpose of Article 28 is not mentioned in the provided text. | What is the purpose of Article 28 of the Decree-Law? |
No, payments or benefits to Connected Persons are only deductible if they meet the specified conditions mentioned in Article 36 of the Decree-Law. | Are all payments or benefits to Connected Persons deductible? |
No, the Market Value must be determined based on objective factors and the actual value of the service, benefit, or otherwise provided by the Connected Person. | Can the Market Value of the service, benefit, or otherwise provided by the Connected Person be determined subjectively? |
The purpose of Cabinet Decision No. 44 of 2020 is to organize reports submitted by multinational companies. | What is the purpose of Cabinet Decision No. 44 of 2020? |
The Explanatory Guide is about Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses. | What is the Explanatory Guide about? |
Article 22 specifies the types of income and related expenditure that shall not be taken into account in determining Taxable Income. | What does Article 22 specify? |
The applicable conditions must be satisfied or a Taxable Person elects to claim the exemption from Corporate Tax under Article 24. | What are the conditions for not considering certain income and expenditure in Taxable Income? |
The purpose of Clause 3 is to empower the Authority to monitor compliance of a Resident Person that applied for Small Business Relief. | What is the purpose of Clause 3? |
The Authority can request any relevant documents and records from a Resident Person that applied for Small Business Relief. | What can the Authority request from a Resident Person that applied for Small Business Relief? |
The intention is to further reduce the compliance burden. | What is the intention behind not requiring Transfer Pricing documentation under Article 55? |
The subject of Chapter Seven is Exempt Income. | What is the subject of Chapter Seven? |
Article 24 allows a Taxable Person to claim the exemption from Corporate Tax. | What does Article 24 allow a Taxable Person to do? |
The purpose of Federal Decree-Law No. 47 of 2022 is to regulate the taxation of corporations and businesses. | What is the purpose of Federal Decree-Law No. 47 of 2022? |
Cabinet Decision No. 44 of 2020 is significant as it organizes reports submitted by multinational companies. | What is the significance of Cabinet Decision No. 44 of 2020? |
The Article number for Exempt Income is Article 22. | What is the Article number for Exempt Income? |
Federal Decree-Law No. 47 of 2022 applies to corporations and businesses. | What kind of companies does Federal Decree-Law No. 47 of 2022 apply to? |
The purpose of Article 24 is to provide an option for Taxable Persons to claim exemption from Corporate Tax. | What is the purpose of Article 24? |
Clause 3 grants the Authority the power to monitor compliance of Resident Persons that applied for Small Business Relief. | What is the authority granted by Clause 3? |
A Taxable Person can be either a Resident Person or a Non-Resident Person. | What is the definition of a Taxable Person in this Decree-Law? |
A Resident Person can be a juridical person that is incorporated or established under the State's legislation, including a Free Zone Person. It can also be a juridical person incorporated or established under the legislation of a foreign jurisdiction but effectively managed and controlled in the State. Additionally, a ... | How is a Resident Person defined in this Decree-Law? |
A Non-Resident Person is a person who does not meet the criteria of a Resident Person as stated in Clause 3 of this Article. Additionally, a Non-Resident Person must not have a Permanent Establishment in the State as defined in Article 14 of this Decree-Law. | What is the definition of a Non-Resident Person in this Decree-Law? |
Income from the disposal of shares or capital rights, income from intellectual or intangible property, and interest income. | What types of income would be considered State Sourced Income in the UAE? |
Income from the disposal of shares or capital rights is sourced to the UAE where the juridical person is incorporated or resident for Corporate Tax purposes. | Where is income from the disposal of shares or capital rights sourced to in the UAE? |
Amounts paid for the use, the right to use, or the granting of permission to use patents, trademarks, trade brands, copyrights, goodwill, and other intangible or intellectual property in the UAE. | What types of intellectual or intangible property income would be sourced to the UAE? |
No, interest income is sourced to the UAE if the interest is paid by a Resident Person. | Does interest income in the UAE depend on the payer and recipient's location and residence? |
Factors such as the nature of income, location and residence of payor and recipient, and Corporate Tax purposes. | What factors determine the sourcing of income in the UAE? |
Yes, sales and distribution activities in the UAE are generally considered State Sourced Income. | Are sales and distribution activities considered State Sourced Income in the UAE? |
Income from intellectual or intangible property is generally sourced to the UAE, regardless of the payer and recipient's location and residence for Corporate Tax purposes. | How is income from intellectual or intangible property sourced in the UAE? |
Yes, income from the disposal of shares or capital rights is sourced to the UAE where the juridical person is incorporated or resident for Corporate Tax purposes. | Is income from the disposal of shares or capital rights sourced to the UAE? |
Income derived from the use, right to use, or granting of permission to use patents, trademarks, trade brands, copyrights, goodwill, and other intangible or intellectual property in the UAE. | What types of intangible or intellectual property income are sourced to the UAE? |
The sourcing of interest income in the UAE depends on whether it is paid by a Resident Person or not. | What determines the sourcing of interest income in the UAE? |
Yes, income from sales and distribution activities in the UAE is generally considered State Sourced Income. | Is income from sales and distribution activities considered State Sourced Income in the UAE? |
Yes, the location and residence of the payer and recipient are relevant factors for the sourcing of income in the UAE, particularly for intellectual or intangible property income. | Is the location or residence of the payer and recipient relevant for the sourcing of income in the UAE? |
Income from the disposal of shares or capital rights, income from intellectual or intangible property, and interest income. | What is considered State Sourced Income in the UAE? |
Interest income is sourced to the UAE if it is paid by a Resident Person. | Where is interest income sourced to in the UAE? |
Yes, the sourcing of income in the UAE can depend on Corporate Tax purposes, particularly in the case of the disposal of shares or capital rights. | Does the sourcing of income in the UAE depend on Corporate Tax purposes? |
Losses realized on the liquidation of a Participation are deductible under Clause 8. | What is deductible under Clause 8? |
Other income that is not directly related to the ownership of a Participating Interest, such as income from services provided to the Participation or Interest income earned under a loan granted to the Participation, is not exempt from Corporate Tax. | Which type of income is not exempt from Corporate Tax? |
The Participation Exemption does not apply when the Participation can claim a deduction for the dividend or other profit distribution made to the Taxable Person under an applicable tax legislation. | When does the Participation Exemption not apply? |
The purpose of Clause 6(a) is to prevent situations of potential double non-taxation that would arise if the Participation can claim a deduction for the dividend or other distribution made to the Taxable Person, and that same dividend or other distribution is not taxed. | What is the purpose of Clause 6(a)? |
Corporate Tax is a form of direct tax levied on the net income of corporations and other businesses. It is sometimes also referred to as 'Corporate Income Tax' or 'Business Profits Tax' in other jurisdictions. | What is Corporate Tax? |
Taxable Persons: UAE companies and juridical persons incorporated or effectively managed in the UAE, Natural persons conducting Business or Business Activity in the UAE, Non-resident juridical persons with a Permanent Establishment in the UAE, Juridical persons established in UAE Free Zones, Withholding Tax: Non-reside... | Who is subject to Corporate Tax? |
Automatically Exempt: Government Entities, Government Controlled Entities specified in a Cabinet Decision, Exempt If Notified: Extractive Businesses, Non-Extractive Natural Resource Businesses, Exempt If Listed: Qualifying Public Benefit Entities, Exempt If Applied And Approved: Public or private pension and social sec... | Who is exempt from Corporate Tax? |
Basis Of Taxation: Resident Person: Taxed on income from both domestic and foreign sources, NonResidentPerson: Taxed only on income derived from sources within the UAE, Residence Definition: Residence is determined by specific factors outlined in the Corporate Tax Law., NoResidenceCriteria: A person not meeting conditi... | How is a Taxable Person subject to Corporate Tax? |
Companies And Juridical Persons: Criteria: Incorporated, formed, or recognized under UAE laws, Juridical persons under mainland legislation, Free Zone regulations, or created by special statute, Foreign companies effectively managed and controlled in the UAE, NaturalPersons: Natural persons conducting Business or Busin... | Who is a Resident Person? |
Definition: Non-Resident Persons are juridical persons without UAE residency but having a Permanent Establishment or deriving State Sourced Income., Taxation: Permanent Establishment: Subject to Corporate Tax on Taxable Income attributable to Permanent Establishment, UAE Income: Subject to Withholding Tax on certain UA... | Who is a Non-Resident Person? |
Definition: A significant presence principle in international tax law used to determine when foreign entities are subject to Corporate Tax., Basis In UAE: Based on Article 5 of OECD Model Tax Convention, Position under Multilateral Instrument, Relevant Commentary of Article 5 and bilateral tax agreements are considered... | What is a Permanent Establishment? |
Taxable Income: Corporate Tax is imposed on Taxable Income earned by a Taxable Person in a Tax Period, Process: Annual imposition, Calculation through self-assessment and Corporate Tax Return filing, Starting with accounting income, adjustments are made to determine Taxable Income., Adjustments Include: Exempt income, ... | What is Corporate Tax imposed on? |
Exempt Income: Definition: Income types not subject to Corporate Tax and related expenditure cannot be deducted., Purpose: Prevent double taxation, Examples: Dividends and capital gains from domestic and foreign shareholdings, Option for Resident Person to exclude income from foreign Permanent Establishment. | What income is exempt from Corporate Tax? |
Deductible Expenses: Principle: Legitimate business expenses wholly and exclusively for deriving Taxable Income are deductible., Adjustments: Certain accounting expenses may not be fully deductible for Corporate Tax purposes., Examples: Interest expenditure (deduction subject to threshold), Dual purpose expenses (porti... | What expenses are deductible? |
Rates: Threshold: AED 375,000, Rate: 0%, Above Threshold: true, Rate: 9%, Qualifying Free Zone Persons: Benefits: 0% Corporate Tax rate on Qualifying Income, Conditions: Adequate substance in UAE, Derive Qualifying Income, No election for standard Corporate Tax rates, Compliance with transfer pricing requirements, Cons... | What is the Corporate Tax rate? |
Rate: 0%, Applicability: Applies to certain UAE sourced income paid to non-residents | What is the Withholding Tax rate? |
Qualifications: Maintain adequate substance in UAE, Derive Qualifying Income, No election for standard Corporate Tax rates, Compliance with transfer pricing requirements, Failure To Meet Conditions: Results in standard Corporate Tax rates. | When can a Free Zone Person be a Qualifying Free Zone Person? |
Formation Conditions: Parent company owns 95% share capital and voting rights of subsidiaries, Same Financial Year and accounting standards, Parent and subsidiaries are resident juridical persons, Exclusions: Exempt Persons and Qualifying Free Zone Persons cannot be part of a Tax Group. | What are Tax Groups, and when can they be formed? |
Requirements: Register and obtain a Corporate Tax Registration Number, File Corporate Tax return within 9 months from Tax Period end, Payment deadline same as filing deadline, Deadlines: Registration on February 28 for Example Ending On May 31, Filing and payment by the end of November for Example Ending On May 31, Reg... | How to register, file, and pay Corporate Tax? |
Steps: Read Corporate Tax Law and supporting information, Determine applicability and obligations, Understand registration, filing, and payment deadlines, Prepare necessary financial information and records, Ongoing: Regularly check official websites for updates and guidance. | How to prepare for Corporate Tax? |
The payment or benefit must correspond with the Market Value of the service, benefit or otherwise provided by the Connected Person and be incurred wholly and exclusively for the purposes of the Taxable Person’s Business. | What is the requirement for a payment or benefit provided by a Taxable Person to its Connected Person to be deductible? |
A Person is considered a Connected Person of a Taxable Person if they are an owner of the Taxable Person, a director or officer of the Taxable Person, or a Related Party of any of the Persons mentioned. | How is a Person considered a Connected Person of a Taxable Person? |
Being a Connected Person determines whether a payment or benefit provided by a Taxable Person is deductible or not. | What is the significance of being a Connected Person? |
A 'Connected Person' refers to someone who is an owner, director, officer, or Related Party of a Taxable Person. | What is the definition of 'Connected Person'? |
Yes, for the payment or benefit to be deductible, it must correspond with the Market Value of the service, benefit or otherwise provided by the Connected Person. | Is there a requirement for the payment or benefit to correspond with the Market Value? |
No, the payment or benefit must be incurred wholly and exclusively for the purposes of the Taxable Person's Business in order to be deductible. | Can a payment or benefit provided by a Taxable Person to its Connected Person be deductible even if it is not incurred wholly and exclusively for the purposes of the Taxable Person's Business? |
The purpose of Article 36 is to regulate payments to Connected Persons and determine the conditions under which such payments are deductible. | What is the purpose of Article 36 of the Decree-Law? |
The general rule is that a payment or benefit provided by a Taxable Person to its Connected Person is deductible if and to the extent it corresponds with the Market Value of the service, benefit or otherwise provided by the Connected Person and is incurred wholly and exclusively for the purposes of the Taxable Person's... | What is the general rule for deductibility of payments or benefits to Connected Persons? |
Yes, there may be exceptions as specified in Article 28 of the Decree-Law. | Are there any exceptions to the deductibility of payments or benefits to Connected Persons? |
The Market Value is determined based on the value of the service, benefit or otherwise provided by the Connected Person. | Who determines the Market Value of the service benefit or otherwise provided by the Connected Person? |
Being a director or officer of the Taxable Person is one of the factors that leads to a Person being considered a Connected Person. | What is the role of being a director or officer of the Taxable Person in determining Connected Person status? |
Yes, a Person can be a Connected Person if they are a Related Party of any of the owners, directors, or officers of the Taxable Person. | Can a Person be a Connected Person of a Taxable Person without being an owner, director or officer? |
The purpose of Article 28 is not mentioned in the provided text. | What is the purpose of Article 28 of the Decree-Law? |
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