Exempting Certain Persons from Corporate Tax for the Purposes of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses
The Cabinet:
- Having reviewed the Constitution,
- Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses, and its amendments,
- Pursuant to what was presented by the Minister of Finance and upon the approval of the Cabinet,
Decided:
Article (1) Definitions
Definitions in Federal Decree-Law No. 47 of 2022 referred to above shall apply to this Decision.
Article (2) Exemption from Corporate Tax
For the purposes of paragraph (i) of Clause (1) of Article (4) of Federal Decree-Law No. 47 of 2022 referred to above, a Taxable Person incorporated or established under the applicable legislation of a foreign jurisdiction that is wholly owned and controlled by an Exempt Person specified in paragraphs (a), (b), (f) and (g) of Clause (1) of Article (4) of Federal Decree-Law No. 47 of 2022 referred to above shall be exempt from Corporate Tax, provided it conducts any of the following:
- Only undertakes part or whole of the activity of the Exempt Person.
- Is engaged exclusively in holding assets or investing funds for the benefit of the Exempt Person.
- Only carries out activities that are ancillary to those carried out by the Exempt Person.
Article (3) Publication and Application of the Decision
This Decision shall be published in the Official Gazette and shall be effective from 1 June 2023.
Mohammed bin Rashid Al Maktoum
Prime Minister
Issued by us:
On: 4 / Dhuʻl-Qiʻdah / 1446H
Corresponding to: 2 / May / 2025
Important Notice
The above extract has been provided for reference only and is based on information available in the public domain at the time of publication, which is subject to change. This does not constitute any form of advice or recommendation and therefore cannot be relied on to cover specific situations. We highly recommend that you consult with a qualified tax advisor in the UAE for personalized guidance based on your specific business circumstances. We accept no duty of care or liability for any loss occasioned to any person acting or refraining from action as a result of any material in this publication. Please refer to the following resources for the official and up-to-date information on the UAE Corporate Tax legal framework:- UAE Ministry of Finance: https://mof.gov.ae/tax-legislation/; and
- UAE Federal Tax Authority: https://tax.gov.ae/en/Legislation.aspx