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The UAE Tax Case Study: Intra-Group Interest-Baring loans, tax and related legal issues

Intra-group loans are widespread all over the world. Tax rules require taxing interest Arm's Length. But does the provision of a loan require a special financial license? Do you need to expand your trading or other license? How the UAE federal...

The UAE Tax Case Study: A bank-managed portfolio and the 0% Corporate Tax Rate

A company is operating in a UAE free zone. Upon agreement with a bank, the latter invests in shares and other securities on behalf of the Company to earn income associated with the holding and sale of these securities. Does income earned...

Case Study: Exemption and the 0% Cor-porate Tax Rate – Interplay

Some details related to de minimis in UAE Corporate Taxation has been addressed in this Case Study. Read more in the article of Andrey Nikonov, Senior Partner, and Maria Nikonova, Partner.

Case Study: Full Time employees only to benefit 0% Corporate Tax Rate?

Recent UAE Cabinet Decision introduced full employment as feature for adequate substance, requiring to enjoy 0% Corporate Tax rate in the UAE free zones. This is illustrated in the case study. Read more in the article of Andrey...

0% for the Trading of Commodities. A designated zone is not required. But do you have to sell your goods on an exchange to qualify?

On 27 October 2023, the UAE’s Minister of Finance released Decision No. 265 replacing Decision No. 139 of 1 June 2023, previously in effect, with an updated list of Qualifying Activities. The replacement shall be applied retroactively...

0% Corporate Tax for IP but 9% for embedded IP used in Qualifying Activities, and more …

In this article we address a few of the issues in the recent Decisions of the UAE’s Cabinet. Read more in the article of Andrey Nikonov, Senior Partner, and Maria Nikonova, Partner.

Distribution outside of the UAE. Case study

A distribution company is incorporated in a designated zone in the UAE. Its facilities are located in the designated zone from where its employees buy the goods in China, resell them to Indian customers, and arrange shipment of...

IP Assets Case Study: TP, DEMPE, risks and reward + ESR on top

The UAE’s FTA issued Transfer Pricing Guide No. CTGTP1 this week. The FTA sets forth the following hierarchical algorithm... Read more in the article of Andrey Nikonov, Senior Partner.

Place of Effective Management: vulnerable issues

Concept of POEM in the UAE Corporate Taxation. Article 11(3)(b) of the Corporate Tax Law deems as a tax resident ‘a juridical person that is incorporated or otherwise established or recognized under the applicable legislation...