Analytics and brochures

This brief explores the dual status of offshore companies, which have dual status under corporate legislation. On the one hand, they are legal entities acting independently. On the other hand, they possess the ‘capacity, rights and privileges of a natural person. Read more in the article of Andrey Nikonov, Senior Partner.

On October 3rd, we partnered with STI Taxand to host a joint webinar on the intricate challenges of transfer pricing within Free Zones under the UAE Corporate Tax framework. Read more in the article of Andrey Nikonov, Senior Partner.

One more extract from our IP webinar last week. This group of slides addresses cases where one intellectual property item is acquired to generate another one. Acquisition costs decrease the share of income from IP when applying the 0% corporate tax rate. Should this unfavorable treatment apply to cases where one IP is integrated into another? Read more in the article of Andrey Nikonov, Senior Partner.

In October 2023, the UAE retrospectively introduced tax benefits for the ownership and exploitation of intellectual property. Income from patents or software and other qualifying IP assets can be in the scope of the 0% Corporate Tax rate. The regime is guided by the OECD guidelines highlighted in the final BEPS report on Action 5. Read more in the article of Andrey Nikonov, Senior Partner.

On November 15, 2024, a significant amendment to the UAE VAT Executive Regulation will come into effect, reshaping the way VAT is applied to the export of services. Previously, Article 31(1)(a) permitted zero-rating for services supplied to recipients who did not have a place of residence in the UAE and who was outside the State at the time the services were performed. The amended version introduces a new condition. This amendment affects services deemed to be supplied within the UAE or Designated Zones under specific provisions of Articles 30 and 31 of the VAT Law. As a result, certain services, even those performed for non-residents, may no longer be eligible for zero-rating. This article explores the practical implications of this new rule on various types of services. Read more in the article of Andrey Nikonov, Senior Partner.

This study is part of a wider job that we have done to answer the question of which "similar entities" can obtain Family Foundation (transparent) status in addition to foundations and mainland trusts. A candidate cannot engage in activity that constitutes Business if the same activity is carried out by an individual (settler, founder or beneficiary). Personal Investments and Real Estate are excluded from the definition of Business. However, the FTA continually reminds us that Personal must not be confused with Business investments. The distinction is unclear. The research aims to gain more certainty on this issue. Read more in the article of Andrey Nikonov, Senior Partner.