Article 1 – Definitions In the application of the provisions of this Decree-Law, the following words and expressions shall have the meanings assigned against each,...
Article 2 – Imposition of Corporate Tax Corporate Tax shall be imposed on Taxable Income, at the rates determined under this Decree-Law, and payable to...
Article 3 – Corporate Tax Rate Corporate Tax shall be imposed on the Taxable Income at the following rates: 0% (zero percent) on the portion...
Article 4 – Exempt Person The following Persons shall be exempt from Corporate Tax: A Government Entity. A Government Controlled Entity. A Person engaged in...
Article 5 – Government Entity A Government Entity shall be exempt from Corporate Tax and the provisions of this Decree-Law shall not apply to it....
Article 6 – Government Controlled Entity A Government Controlled Entity shall be exempt from Corporate Tax and the provisions of this Decree-Law shall not apply...
Article 7 – Extractive Business A Person shall be exempt from Corporate tax and the provisions of this Decree-Law shall not apply to its Extractive...
Article 8 – Non-Extractive Natural Resource Business A Person shall be exempt from Corporate tax and the provisions of this Decree-Law shall not apply to...
Article 9 – Qualifying Public Benefit Entity A Qualifying Public Benefit Entity shall be exempt from Corporate Tax where all of the following conditions are...
Article 10 – Qualifying Investment Fund An investment fund may apply to the Authority to be exempt from Corporate Tax as a Qualifying Investment Fund...
Article 11 – Taxable Person Corporate Tax shall be imposed on a Taxable Person at the rates determined under this Decree-Law. For the purposes of...
Article 13 – State Sourced Income Income shall be considered State Sourced Income in any of the following instances: Where it is derived from a...
Article 14 – Permanent Establishment A Non-Resident Person has a Permanent Establishment in the State in any of the following instances: Where it has a...
Article 15 – Investment Manager Exemption 1. For the purposes of Clause 6 of Article 14 of this Decree-Law, an Investment Manager shall be considered...
Article 16 – Partners in an Unincorporated Partnership 1. Unless an application is made under Clause 8 of this Article, and subject to any conditions...
Article 17 – Family Foundation 1. A Family Foundation can make an application to the Authority to be treated as an Unincorporated Partnership for the...
Article 18 – Qualifying Free Zone Person 1. A Qualifying Free Zone Person is a Free Zone Person that meets all of the following conditions:...
Article 19 – Election to be Subject to Corporate Tax 1. A Qualifying Free Zone Person can make an election to be subject to Corporate...
Article 20 – General Rules for Determining Taxable Income 1. The Taxable Income of each Taxable Person shall be determined separately, on the basis of...
Article 21 – Small Business Relief 1. A Taxable Person that is a Resident Person may elect to be treated as not having derived any...
Article 22 – Exempt Income The following income and related expenditure shall not be taken into account in determining the Taxable Income: Dividends and other...
Article 23 – Participation Exemption 1. Income from a Participating Interest shall be exempt from Corporate Tax, subject to the conditions of this Article. 2....
Article 24 – Foreign Permanent Establishment Exemption 1. A Resident Person can make an election to not take into account the income, and associated expenditure,...
Article 25 – Non-Resident Person Operating Aircraft or Ships in International Transportation Income derived by a Non-Resident Person from the operation of aircraft or ships...
Article 26 – Transfers Within a Qualifying Group 1. No gain or loss needs to be taken into account in determining the Taxable Income in...
Article 27 – Business Restructuring Relief 1. No gain or loss needs to be taken into account in determining Taxable Income in any of the...
Article 28 – Deductible Expenditure 1. Expenditure incurred wholly and exclusively for the purposes of the Taxable Person’s Business that is not capital in nature...
Article 29 – Interest Expenditure Notwithstanding paragraph (b) of Clause 2 of Article 28 of this Decree-Law, Interest expenditure shall be deductible in the Tax...
Article 30 – General Interest Deduction Limitation Rule 1. A Taxable Person’s Net Interest Expenditure shall be deductible up to 30% (thirty percent) of the...
Article 31 – Specific Interest Deduction Limitation Rule 1. No deduction shall be allowed for Interest expenditure incurred on a loan obtained, directly or indirectly,...
Article 32 – Entertainment Expenditure 1. Subject to Article 28 of this Decree-Law, a Taxable Person shall be allowed to deduct 50% (fifty percent) of...
Article 33 – Non-deductible Expenditure No deduction is allowed for: Donations, grants or gifts made to an entity that is not a Qualifying Public Benefit...
Article 34 – Arm’s Length Principle 1. In determining Taxable Income, transactions and arrangements between Related Parties must meet the arm’s length standard as specified...
Article 35 – Related Parties and Control 1. For the purposes of this Decree-Law, “Related Parties” means any of the following: Two or more natural...
Article 36 – Payments to Connected Persons 1. Without prejudice to the provisions of Article 28 of this Decree-Law, a payment or benefit provided by...
Article 37 – Tax Loss Relief 1. A Tax Loss can be offset against the Taxable Income of subsequent Tax Periods to arrive at the...
Article 38 – Transfer of Tax Loss 1. A Tax Loss or a portion thereof may be offset against the Taxable Income of another Taxable...
Article 40 – Tax Group 1. A Resident Person, which for the purposes of this Decree-Law shall be referred to as a “Parent Company”, can...
Article 41 – Date of Formation and Cessation of a Tax Group 1. For the purposes of Article 40 of this Decree-Law, a Tax Group...
Article 42 – Taxable Income of a Tax Group 1. For the purposes of determining the Taxable Income of a Tax Group, the Parent Company...
Article 43 – Currency For the purposes of this Decree-Law, all amounts must be quantified in the United Arab Emirates dirham. Any amount quantified in...
Article 44 – Calculation and Settlement of Corporate Tax The Corporate Tax due under this Decree-Law is settled in the following order: First, by using...
Article 45 – Withholding Tax 1. The following income shall be subject to Withholding Tax at the rate of 0% (zero percent) or any other...
Article 46 – Withholding Tax Credit 1. If a Person becomes a Taxable Person in a Tax Period, the Person’s Corporate Tax due under Article...
Article 47 – Foreign Tax Credit 1. Corporate Tax due under Article 3 of this Decree-Law can be reduced by the amount of Foreign Tax...
Article 48 – Corporate Tax Payment A Taxable Person must settle the Corporate Tax Payable under this Decree-Law within (9) nine months from the end...
Article 49 – Corporate Tax Refund 1. A Taxable Person may make an application to the Authority for a Corporate Tax refund in accordance with...
Article 50 – General anti-abuse rule 1. This Article applies to a transaction or an arrangement if, having regard to all relevant circumstances, it can...
Article 51 – Tax Registration 1. Any Taxable Person shall register for Corporate Tax with the Authority in the form and manner and within the...
Article 52 – Tax Deregistration 1. A Person with a Tax Registration Number shall file a Tax Deregistration application with the Authority where there is...
Article 53 – Tax Returns 1. Subject to Article 51 of this Decree-Law, a Taxable Person must file a Tax Return, as applicable, to the...
Article 54 – Financial Statements 1. The Authority may, by notice or through a decision issued by the Authority, request a Taxable Person to submit...
Article 55 – Transfer Pricing Documentation 1. The Authority may, by notice or through a decision issued by the Authority, require a Taxable Person to...
Article 56 – Record Keeping 1. Notwithstanding the provisions of the Tax Procedures Law, a Taxable Person shall maintain all records and documents for a...
Article 57 – Tax Period 1. A Taxable Person’s Tax Period is the Financial Year or part thereof for which a Tax Return is required...
Article 58 – Change of Tax Period Notwithstanding Article 57 of this Decree-Law, a Taxable Person can make an application to the Authority to change...
Article 59 – Clarifications 1. A Person may make an application to the Authority for a clarification regarding the application of this Decree-Law or the...
Article 60 – Assessment of Corporate Tax and penalties 1. A Person may be subject to a Corporate Tax assessment in accordance with the Tax...
Article 61 – Transitional Rules 1. A Taxable Person’s opening balance sheet for Corporate Tax purposes shall be the closing balance sheet prepared for financial...
Article 62 – Delegation of Power The Minister may delegate his powers under this Decree-Law, in full or in part, to the Authority, where the...
Article 63 – Administrative Policies and Procedures The administrative policies, procedures and general instructions in relation to the requirements imposed on a Person under this...
Article 64 – Cooperating with the Authority All governmental authorities in the State shall fully cooperate with the Authority to carry out whatever is required...
Article 65 – Revenue Sharing Corporate Tax revenues and Administrative Penalties collected under this Decree-Law shall be subject to sharing between the Federal Government and...
Article 66 – International Agreements To the extent the terms of an international agreement that is in force in the State are inconsistent with the...
Article 68 – Cancellation of Conflicting Provisions Any text or provisions contrary to or inconsistent with the provisions of this Decree-Law shall be abrogated.
Article 69 – Application of this Decree-Law to Tax Periods This Decree-Law shall apply to Tax Periods commencing on or after 1 June 2023.
Article 70 – Publication and Application of this Decree-Law This Decree-Law shall be published in the Official Gazette and shall come into effect (15) fifteen...
Article 12 – Corporate Tax Base A Resident Person, which is a juridical person, is subject to Corporate Tax on its Taxable Income derived from...
Article 39 – Limitation on Tax Losses Carried Forward 1. Tax Losses can only be carried forward and utilised in accordance with the provision of...
Article 67 – Implementing Decisions 1. Subject to the powers conferred to the Cabinet under this Decree-Law, the Minister and the Authority shall issue the...