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Who are not subject to the UAE Corporate Tax?


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The Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses, provides the legislative basis for the introduction and implementation of a Federal Corporate Tax in the UAE. The law lists certain entities, subject to fulfilling certain conditions, which are not subject to Corporate Tax.


Certain types of businesses or organisations are exempt from Corporate Tax which is mentioned under Article 4 of 47 of 2022. Conditions for each of the below mentioned exempt categories have been detailed in the Law of 47 of 2022 from Article 5 – Article 10 of the Law.


These Exempt Persons include:

Type of Entity

Corporate Tax Registration

Requirement

Government Entities

Not required to register, unless the Person undertakes a Taxable Business

Automatically exempt

Extractive Businesses

Not required to register for Corporate Tax, unless the Person undertakes a Taxable Business

If notified to MoF and meeting relevant conditions

Non-Extractive Natural Resource Businesses

Not required to register for Corporate Tax, unless the Person undertakes a Taxable Business

If notified to MoF and meeting relevant conditions

Government Controlled Entities (with their mandated activities)

Not required to register for Corporate Tax, unless the Person undertakes a Taxable Business

If listed in a Cabinet Decision and meeting the relevant conditions.

Qualifying Public Benefit Entities

Required to register from 1st October 2023

If listed in a Cabinet Decision and meeting the relevant conditions.

Qualifying Investment Funds

Required to register from 1st June 2024

After application to and approved by the FTA and meeting the relevant conditions.

Public or private pension and social security funds

Required to register from 1st June 2024

After application to and approved by the FTA and meeting the relevant conditions.

Wholly owned and controlled UAE subsidiaries of certain Exempt Person

Required to register from 1st June 2024

After application to and approved by the FTA and meeting the relevant conditions.

In addition to not being subject to Corporate Tax, Government Entities, Government Controlled Entities, Extractive Businesses, Non-Extractive Natural Resource Businesses and Non-Resident Person that derives only State Sourced Income are exempted from any registration imposed by the Corporate Tax Law, unless they engage in an activity which is within the charge of Corporate Tax, as per the Ministerial Decision No. 43 of 2023.

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