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Chapter 6: Exempt Persons | Who Pays No Corporate Tax in UAE? — Transcript

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0:00Hi everyone,
0:02welcome to chapter 6. In chapter six, we
0:04are going to discuss on exempt person.
0:08Exempt person means certain entities are
0:12exempted from UA corporate tax. This is
0:15what we are going to cover. Before
0:17getting into exempt person, uh let me
0:20put a different point which we have
0:22missed in chapter 4 when we discussed
0:25about resident
0:28for corporate tax purpose. Resident for
0:30corporate tax purpose. We discussed in
0:32chapter 4. In chapter four we discussed
0:34about resident juroritical person,
0:36resident natural person. This is what we
0:38have discussed. In resident jurorical
0:41person one more category is coming under
0:46resident which is for foreign companies.
0:48We told like okay in resident jurorical
0:51person uh the any company registered in
0:53UAE be it limited liability partnership
0:57or LLC company or public joint company
1:00they are considering as resident for
1:03corporate tax purpose.
1:05Now what we are going to discuss is how
1:07a foreign company can become uh resident
1:10for corporate tax purpose. This is one
1:12part which we missed in chapter 4. So
1:15before uh like you know getting into the
1:17new topic I thought I will cover this as
1:20well. A foreign company can become tax
1:23resident in UAE when that foreign
1:26company has a place of effective
1:29management in UAE.
1:35Place of effective management in UAE.
1:37What is place of effective management?
1:39In short form, it is called P O M.
1:45POE.
1:47when the there is a foreign company and
1:49that foreign company is effectively
1:52controlled and managed from UAE. In that
1:54case that company is considered as
1:58resident for tax purpose in UAE.
2:01Now what could be the possibilities?
2:03I'll just give an example to you. If
2:05there is a company which is registered
2:07in BVI or Cayman Island,
2:11these are island countries
2:14like practically speaking, no one cannot
2:16really go and run the business in such
2:18type of uh island countries. In this
2:23situation, let's say if this BBI company
2:25or Cayman Island company, the owner
2:29is in UAE,
2:34the decision maker,
2:37let's say director is also in UAE. That
2:41means the company is effectively
2:43controlling and managing from UAE, not
2:46from Cayman. In this situation, UAE
2:49corporate tax law explained that in such
2:52scenarios, these companies are
2:54considered as resident
2:59resident for corporate tax purpose. When
3:02a company become resident for corporate
3:04tax purpose, what is going to happen? We
3:06already discussed what is their tax
3:08base? Their tax base is
3:11worldwide
3:14income that such companies are going to
3:17pay taxes on their worldwide income. And
3:20when a foreign company which has a POEM
3:24in UAE and they become a resident then
3:27they need to register. When they need to
3:29register, they need to register within 3
3:32months from the day
3:35POM is established.
3:40This is their registration requirement.
3:42Once they're registered, what is the
3:45next step they need to follow? They need
3:47to follow the return filing. When they
3:49need to follow the return filing, they
3:51need to follow the return filing on
3:52annual basis. And we already discussed 9
3:55months from the end of uh tax period.
3:58They need to submit the tax return. This
4:00much we have discussed. Now the whole
4:02point is that just because a company
4:05registered outside UAE and uh that
4:09company is getting managed from UAE in
4:12that situation that company is also
4:14considered as a resident for corporate
4:16tax purpose and they need to follow the
4:18all the regulations which need to be
4:20followed by the uh by the uh resident
4:24person. So this one point I thought I
4:27will discuss before getting into the new
4:29chapter. Now what we are going to
4:31discuss today is on exempt person.
4:35Who is exempt person? So before exempt
4:37person let me give a clarity to you.
4:40Exempt person is not equal to
4:45not equal to exempt income.
4:49What is the difference between exempt
4:51person and exempt income? When it comes
4:53to exempt person, the CT law, the
4:56corporate tax law is telling that they
4:58are not subject to corporate tax. They
5:01don't require to submit a tax return.
5:04When it comes to exempt income, exempt
5:07income is that the company is taxable
5:11but certain income of that company is
5:13exempt from corporate tax. We will
5:16discuss uh what are all the type of
5:18exempt income the conditions all those
5:20things we are going to discuss in the
5:22coming chapters. So when it comes to
5:24exempt person please make these things
5:26clear that exempt person is not is equal
5:28to exempt income.
5:31Now who are exempt person this is
5:34explained in article 4 of UA corporate
5:37tax law. Article four of UA corporate
5:40tax law explain who all are the exempt
5:43person for corporate tax purpose. Now
5:46followed with that article five uh to
5:49article 10 the six articles given the
5:52breakup of what is told in article 4.
5:55Article four gave a list of exempt
5:57person. Then from article 5 to article
5:5910 each exempt person is explained. Now
6:03for easy discussion let me divide the uh
6:06exempt person into three category.
6:09Category number one automatically
6:11exempt.
6:15Category number two exempt if notified
6:20in the
6:22ministry of
6:24finance.
6:26Exempt category 3
6:29exempted
6:32if listed in
6:36cabinet decision.
6:38Four categories in fact other exempt
6:41person.
6:43Four categories. Category one they are
6:45automatically exempt from corporate tax.
6:47Category two if they notified in the
6:50ministry of finance then they are
6:51exempted. Category three exempted if
6:54listed in cabinet decision exempt for
6:57other exempt person these four
6:58categories. Now let's understand who is
7:01automatically exempt from corporate tax.
7:04There are two entities which are
7:06automatically exempt from corporate tax.
7:09One is government entities. Second one
7:11is
7:13government
7:15controlled entities.
7:19These are the two categories of entities
7:21who are automatically exempt from
7:24corporate tax u automatically exempt
7:27from corporate tax. Now let's take the
7:30first case which is government entity
7:32where it is explained about government
7:34entity. It is explained in article five
7:38of corporate tax law. Article five is
7:40explained about government entities.
7:44What go what article five is talking
7:47about government entity? Article 5 is
7:49talking that if the government is doing
7:54the activity
7:56which is in the
8:00sovereign capacity
8:04then they are considered as exempt
8:06person. I I'll give an example let's say
8:09police
8:12or let's say army. These sort of things
8:14if a b government is doing in the
8:17sovereign capacity then such entities
8:20are considered as exempt person and they
8:22are automatically exempt from corporate
8:25tax. Now what will happen if government
8:30is conducting
8:32any business activities.
8:35This also explained in article 5. In
8:39that case uh article five is explained
8:41if government
8:44is doing business through trade license.
8:50Trade license then that trade license
8:54business
8:56must register for corporate tax only
8:58that one only that particular trade
9:01license must register for corporate tax.
9:04This is also explained in article five
9:06that if a government is doing anything
9:09in their sovereign capacity, they are
9:11exempt from corporate tax. If they are
9:14doing anything uh like you know through
9:16trade license as a business activity,
9:18then that particular trade license is
9:20subject to corporate tax.
9:23Now what will happen if the government
9:25is doing something in the sovereign
9:27capacity? No need to register for
9:31corporate tax. No need to register for
9:33corporate tax at all. They are
9:35automatically exempt from corporate tax
9:37law. What will happen if the uh
9:39government entities are doing uh certain
9:42business activity through trade license?
9:44Then in that case
9:47that trade license required to register
9:51for corporate tax.
9:54This is about article five which is
9:56government entities. Now let's discuss
9:59about article uh six which is
10:02governmentont controlled entities.
10:04Government controlled entities is
10:05explained in article six. What is
10:08explained in article six that if a
10:11entity
10:12which is 100%age controlled by
10:15government there could be a certain
10:16situation that u some some charitable
10:20organization which is controlled by
10:22government. I will just put this example
10:25charitable
10:27organization
10:30controlled by government.
10:33In this situation they are fully
10:36controlled by government entities and
10:39plus what they need to do they are doing
10:43mandated activities.
10:46they are doing certain activities which
10:48are mandated
10:50as per
10:52cabinet decision.
10:55Now in article six of corporate tax law
10:58it is explained that if a government
11:00controlled entity is conducting any
11:02mandated activities as per the cabinet
11:04decision please note that this cabinet
11:08decision is not at published. It is not
11:11at published. So we don't know what uh
11:14this cabinet decision is talking about.
11:17In that situation they are exempt. If a
11:21government controlled entity they are
11:23fully controlled by government and
11:25conducting mandated activities
11:27uh as per the cabinet decision then they
11:30are automatically exempt from corporate
11:32tax. If the government controlled entity
11:36is explained in cabinet decision that
11:39means they are automatically exempt.
11:43If no then they need to they are not
11:46automatically exempt or they need to
11:48they are not exempt.
11:52When they we are telling they are
11:53automatically exempt immediately things
11:56need to come to your mind is that no
11:58need to do corporate tax registration in
12:00this situation city registration will be
12:03required.
12:06This is about article 5 and article 6.
12:09Now just a quick summary article five
12:11government if government is doing
12:13something in the sovereign capacity they
12:15are automatically exempt no need to
12:17register for corporate tax. If
12:18government is conducting any uh business
12:21activity through trade license then that
12:24particular trade license required to
12:26register for corporate tax. Next
12:28category government controlled entity.
12:30If any entity which is fully controlled
12:33by government and they are into mandated
12:36activities as per cabinet decision, the
12:38cabinet decision is not published then
12:41they are also coming under automatic
12:43exemption.
12:44Now let's move to the exempt category
12:48which is notified in ministry of
12:51finance. Who is coming in this? Here
12:52also there are two categories coming.
12:55First category
12:57business into extraction
13:01of natural resources.
13:05Why this particular business activity is
13:08exempt from corporate tax? The reason is
13:10that they are already paying a tax
13:12called emirate
13:15level taxation.
13:18Emirate level taxation. Uh you think of
13:20a situation a natural extraction
13:22resource company. they are extracting
13:25the natural resource of the country. Uh
13:27we will take an example let's say petrol
13:35petroleum products or gas they're
13:38extracting from the natural resource of
13:41the country particularly telling it is
13:44for the emirate. So each emirate decided
13:46that before the corporate tax is
13:49implemented if anyone is doing any
13:51extraction business they are doing the
13:53extraction of the natural resource of
13:55that particular emirate that emirate has
13:57the right to tax.
14:00Now this tax has different different
14:02percentage depends on the emirates and
14:04it can go up to 55%age. So before
14:08corporate tax come in picture already
14:10these businesses are paying up to 55%age
14:14emirate level taxation
14:17and they are getting approval
14:21from
14:23authority
14:27to conduct this activity
14:31to conduct the uh extraction activity.
14:34They obtained approval plus what they
14:38need to do and they need to
14:41notify ministry of finance that yes we
14:44are uh we have the approval from
14:47authority we are already paying emirate
14:49level taxation this they need to notify
14:51to the ministry of finance in that case
14:54they are exempt from corporate tax
14:58they're exempt from corporate tax and no
15:01need of
15:04CT registration.
15:07No need of CT registration. [music]
15:09Where extraction business is explained?
15:11It is explained in article 7 of
15:13corporate tax law. Now
15:16what is the next category which is again
15:19the second category what we discussed
15:21exempted if notified to ministry of
15:23finance. The second category is non
15:26extraction
15:28of natural resource business.
15:32they are not doing direct extraction of
15:34extraction business. Maybe they are into
15:36the refining or they are into the uh
15:38transportation all this kind of uh
15:41activity
15:42but they are dealing with the natural
15:44resources. Then they are also exempt
15:47from corporate tax. The conditions are
15:49similar that they must be paying emirate
15:52level taxation. they got approval from
15:55uh they got approval from the relevant
15:58authority to do this business and they
16:00have notified to the ministry of
16:02finance. These three condition need to
16:04be satisfied by the non uh extraction of
16:08natural resource business as well. In
16:10that case they are also exempt from
16:12corporate tax and they don't need to do
16:14any CT registration. This is the second
16:17category.
16:19Now moving to the third category,
16:21exempted if listed in cabinet decision.
16:24Exempted if listed in cabinet decision.
16:29Here the exempt person is qualifying
16:33public benefit entity
16:38and it is explained in article
16:429 of the corporate tax law. Qualifying
16:46public benefit entity is is an entity
16:48which is purely for the benefit of the
16:51public. It can be a educational
16:54institution. It can be sports, it can be
16:57charitable,
16:59it can be anything. It is 100%age for
17:02the benefit of the public plus uh what
17:07what additional condition they need to
17:08satisfy that their name is listed in the
17:14cabinet decision. Now which cabinet
17:17decision there is a cabinet decision
17:19published for this which is cabinet
17:21decision number 37.
17:23There is a cabinet decision and this
17:25cabinet decision has given the full list
17:27of entities which are considered as
17:30public benefit entities and if any
17:32entity who are falling in that public
17:35benefit entity or in listed in that
17:37particular cabinet decision then they
17:40are exempted from corporate tax.
17:44Now do they require to register? Yes,
17:46they need to register for corporate tax.
17:51First two category we already discussed
17:53if they satisfy certain condition they
17:56need to uh they don't need to register
17:58for corporate tax. Now qualifying public
18:01benefit entity what we told uh they are
18:04fully for the benefit of the public. It
18:06can be educational, religious,
18:08charitable or like you know sports
18:10related it can be anything as long as
18:12that entity name is listed in cabinet
18:15decision. Cabinet decision number 37.
18:1837. I believe it is 37 of 2023.
18:24We will verify that
18:26in that case they are exempt from
18:29corporate tax. Do they require to
18:31register? Yes, they have an obligation
18:33to register for corporate tax.
18:37Now the fourth category other exempt
18:40person. In other exam person it is
18:44qualifying
18:47investment fund.
18:49The previous one is qualifying public
18:52benefit entity. This one is qualifying
18:54investment fund. Where it is explained?
18:56It is explained in article 10 of the
18:59corporate tax law. Now who is qualifying
19:01investment fund? Any investment fund. Uh
19:05I hope you guys know the concept of
19:07investment fund. Investment fund is
19:08nothing but a like you know a regulated
19:12entity. They have an they have the right
19:15to collect the fund from the public and
19:18like you know public like you and me can
19:20invest in such investment fund and they
19:23will invest this money into different
19:26different business or shares or it can
19:28be anything they will they will uh
19:30invest and when they get a profit out of
19:33it the profit will be shared to the
19:36investor. This is the whole idea of
19:38investment fund. So if is all investment
19:41funds are eligible for exemption. No.
19:44There are certain investment funds which
19:46are eligible for exemption from
19:49corporate tax purpose.
19:51Now what are all these type of what are
19:53all the condition that is what we are
19:55going to discuss. First one the
19:58investment fund is regulated by
20:00authority.
20:02This is the first condition. Such
20:03investment funds are regulated by
20:06authorities. That means they have
20:08obtained certain approvals from the
20:10authority to collect the investment from
20:12the public and do the investment
20:15activity.
20:16Second one,
20:18the investment fund is not restricted to
20:21certain people. It is widely available
20:24for public
20:26or they are doing
20:31trading in regulated stock exchange.
20:36So such investment funds they are either
20:40they are either like you know widely
20:42available for public or they are doing
20:45trading in the regulated stock exchange
20:48either of these things.
20:51Then third condition the purpose of
20:54investment fund
20:58not corporate tax avoidance.
21:02Now someone who is setting up such kind
21:03of uh investment fund the purpose of
21:06setting up such investment funds are not
21:09avoidance of corporate tax. Now let me
21:12give you an idea. There is an particular
21:14article in the UA corporate tax law
21:16which is article 50. This article 50 is
21:20talking about general anti-
21:26avoidance
21:28rule means
21:31in short we can call GAR
21:35any business who are making some changes
21:37or starting new business closing
21:40business or splitting business for the
21:43purpose of corporate tax benefit that
21:45means they are violating the condition
21:48of article 50 means they are doing this
21:50for corporate tax avoidance purpose then
21:53that is not allowed. This is what
21:54discussed in the article 50. It it has
21:57given certain examples also or certain
22:00situation uh where someone is doing some
22:03business restructuring for the benefit
22:05of corporate tax then it is not allowed.
22:08This is what explained in article 15.
22:12So qualifying investment funds they are
22:14regulated by authority and widely
22:17available for public or they are trading
22:19into the uh regulated stock exchange and
22:21purpose of uh setting up the qualifying
22:25investment fund is not u corporate tax
22:28evasion means they are complying with
22:30the article 50 which is general and
22:33avoidance regulations.
22:36Now the next one is public and
22:41private
22:45pension comma
22:48social security fund.
22:53If any public pension fund or private
22:56pension fund or social security fund
22:58then okay before that let me uh fill
23:03these things. When it comes to
23:04qualifying investment fund also they
23:07need to register for corporate tax
23:11and they need to submit the
23:14annual declaration. It's not tax return.
23:16Actually there is a difference between
23:18annual declaration and tax return.
23:21Business required to submit the tax
23:24return. Whereas certain entities who are
23:27having certain benefits in instead of
23:30filing the tax return they need to
23:32submit the annual uh declaration stating
23:35that yes they are still satisfying the
23:38condition to be exempt. It is applicable
23:41for qualifying investment fund when we
23:43discussed about family foundation again
23:45the same annual declaration is coming.
23:47So wherever annual declaration is coming
23:50uh please make your understanding very
23:51clear that it is not tax return. Annual
23:54declaration is stating that yes still
23:58they are satisfying the condition to
24:00keep their status. If they are exempt it
24:02is exempt person. This is called annual
24:05declaration. So the qualifying
24:06investment fund required to register
24:08also and submit the annual tax
24:11declaration also.
24:13Moving into the next exempt person which
24:15is
24:18private public uh pension and social
24:20security fund. Now where it is explained
24:22in corporate tax law it has not given
24:24much details. Instead there is a
24:27ministerial decision ministerial
24:28decision 115 of 2023. It has given a
24:33clarity on who is eligible to become
24:36exempt if they are into private and uh
24:40public pension and social security fund.
24:43Now here what are all the conditions
24:45explained in ministerial decision 115 of
24:482023. First one is that
24:52the assets under the pension fund are
24:56for pension plan.
24:58This is the first condition. If any
25:00pension fund is there the assets under
25:02the pension fund are for the pension
25:05plans or for the social security
25:07purpose. Second thing,
25:11members have the
25:14right to
25:17claim the benefits.
25:21Members have the right to claim the
25:22benefits. Anyone who is investing in or
25:25like you know putting their money into
25:27such pension fund, those members have
25:30the right to claim the benefit. See the
25:32idea of pension fund is that u like you
25:35know there is different countries are
25:37having different terminologies
25:39let's say a provident fund kind of thing
25:43that during the uh employment the
25:46employee and employer will contribute
25:48and this money will be put it in some
25:50funds pension fund and when that person
25:53is uh retiring from the job or some
25:56unforeseen situation where permanent
25:59disability or death of that person that
26:01pension fund will be given to the uh
26:04person or his legal. This is the concept
26:08of pension fund. Now the conditions what
26:10we are discussing one the assets are for
26:13the pension plan or social security
26:15purpose and the members have the right
26:18to claim the benefit and the uh third
26:21condition is that there is a independent
26:26auditor
26:27for the for such fund.
26:32There need to be an independent auditor
26:34who need to audit this uh fund on a
26:36year-on-year basis and they need to
26:38submit the uh submit the
26:42report to the authority. These are the
26:45three conditions to for a public or
26:48private pension fund to become exempt
26:51from corporate tax purpose.
26:55Now let's discuss. So before getting
26:57into the next uh topic let me just give
27:01give a quick review that we are
27:03discussing article 4 to article 10.
27:06Article 4 is giving a list of exempt
27:09person. List of exempt person. Then from
27:11article 5 to 10 they have explained uh
27:14who all are the exempt person. We
27:16classified it into four category. One is
27:18automatically exempt. Second is if
27:21notified to ministry of finance. Third
27:22one if listed in the cabinet edition.
27:24Fourth one others. In automatically
27:26exempt we told article 5 government
27:28entities if they are doing anything in
27:30their sovereign capacity then they are
27:32exempt no need to register for corporate
27:34tax. If they are conducting any business
27:36activity government is conducting any
27:38business activity through trade license
27:40then that trade license required to
27:41register for corporate tax. Government
27:44controlled entity entities which are
27:46fully controlled by government and they
27:48are conducting the mandated activities
27:51as per the cabinet decision. this
27:52cabinet decision is not at published
27:55then they are also exempt no need to
27:57register for corporate tax purpose. Then
28:00we discuss the second category exempt if
28:02notified in the ministry of finance.
28:04Article 7 extraction of natural
28:07resources and article 8 non-extraction
28:09of natural resource business. Why they
28:11are exempt? They are already paying
28:14emirate level taxation because they are
28:16doing the extra extraction or
28:17non-extraction business from the natural
28:20on the natural resource of the
28:22particular emirate. Different emirate is
28:24taxing different percentage. It can come
28:27up to 55%age.
28:29Additionally, they need to get uh
28:31relevant approval from the authority and
28:34they need to notify to the ministry of
28:36finance. In that case, they are exempt
28:37from corporate tax. No need to register
28:39for corporate tax. Next is article 9
28:42qualifying public benefit entity. It is
28:44purely for the benefit of the public. It
28:46can be religious, educational, sports,
28:48charitable. It can be anything uh
28:50related to that. The condition is that
28:53the name of the entity is listed in
28:55cabinet edition number 37 of 2023.
28:59Do they require to register for
29:00corporate tax? They're required to
29:02register for corporate tax and maintain
29:04their exempt status. Then article 10 is
29:07explaining about investment fund.
29:09Investment fund. What is the investment
29:11fund? Means uh a fund which can where
29:14the pe uh public can put the money and
29:16fund will manage the money and they will
29:19reinvest in multiple things and get
29:22benefit out of it. What is the first
29:24condition? It must be regulated by
29:26authority. Second thing either it is
29:28widely available for public or uh they
29:31are doing the trading through regulated
29:33stock exchange and the purpose of
29:35setting up the fund is not corporate tax
29:37avoidance means they are complying with
29:39the article 50 which is general and
29:41avoidance rule. Do they require to
29:43register? Yes, they required to register
29:45and submit the annual declaration. Then
29:47the last exempt person which is public
29:50uh and private pension and social
29:52security.
29:53Did the corporate tax law has given a
29:55separate article for this? No, instead
29:57there is a ministerial decision
29:58published for uh uh public and private
30:01pension and social security fund.
30:03Ministerial decision number 115 of 2023.
30:06What what are all the conditions
30:08explained in the ministerial decision?
30:10Assets that kept in the uh fund is for
30:13the pension plans or for the social
30:16security. Then the members have the
30:18right to claim the benefits and there
30:20should be an independent auditor to uh
30:23monitor the fund. These are the
30:25conditions.
30:27Now when any entity become exempt person
30:33they are not allowed certain things.
30:37First thing means they are not allowed
30:39to create a tax group.
30:43Tax group is explained in article 40 to
30:4742.
30:49We'll discuss that exempt persons are
30:52not allowed to create a tax group. There
30:54is one exception for that that also we
30:56will discuss. Second thing exempt person
30:59is not eligible for
31:02small business relief.
31:08Third one small business relief we have
31:10discussed multiple times. Third one
31:15exemp person is not eligible for
31:19article 27. What is article 27 is
31:22talking? Business restructuring
31:28relief
31:30again yet to discuss.
31:33Fourth one, exempt persons are not
31:35eligible for relief under article 26.
31:38Article 26 talking about qualifying
31:40group relief. again yet to discuss.
31:45And finally, exempt persons are not
31:48eligible for
31:53transfer of losses. Again, yet to
31:55discuss as per article 38.
32:00As per article 38. So when any entity
32:03become exempt person they are all they
32:06are blocked from getting these sort of
32:08benefits which are available for taxable
32:11person.
32:14Another thing that what we need to
32:16understand that exempt person
32:21may require to register for corporate
32:24tax. We we explained that c certain are
32:27automatically exempt certain are exempt
32:30while notifying certain required to
32:32register.
32:34Uh all this we have discussed.
32:37Next thing exempt person
32:40will not submit
32:43corporate tax return.
32:46Instead they may submit
32:50annual declaration.
32:53This is what another point which is
32:56relevant for exam person.
33:00So with this we are going to uh finish
33:02today's session and what we are going to
33:04discuss. Now let's take a step back. We
33:07have discussed six chapters. We
33:09discussed the fundamentals. We discussed
33:11about the uh decree law, the cabinet
33:15decisions and then we discussed about uh
33:18uh you know taxable income taxable uh
33:21person. Now we discussed on exempt
33:23person. Now we need to take a step back
33:26and we need to discuss so far what we
33:30have discussed we need to see it in the
33:32tax law. What we are going to discuss in
33:35next session?
33:37We are going to see so far what we have
33:40discussed how it is written in the law.
33:42You need to be it is very important that
33:44you need to be familiar with the uh law
33:47and how to read the law because unless
33:51you get an understanding that how to go
33:54back to the law decisions and read it
33:57mean so far like you know today what we
33:59are discussing maybe after some time
34:01that things will get changed but in
34:03order to get updated you need to be very
34:05familiar with the law and the decision
34:07and how to read. This is what we are
34:09going to discuss in uh next uh session
34:13and we are going to touch upon all the
34:16articles and decisions so far we have
34:19discussed. So to give an idea we are
34:22going to discuss federal decree law
34:24number
34:2747 of 2022 which is corporate tax law.
34:31In corporate tax law which all article
34:32we are going to cover is one is article
34:351 to article 15 we are going to read in
34:38the law and additionally we are going to
34:41read article 45
34:44uh if you remember what is article 45
34:46withholding tax and article 48. Article
34:5148 is on the uh accounting records and
34:54then article 50 which we discussed today
34:57general and the avoidance rule. This
35:00many articles we are going to discuss in
35:02the uh next session and we are going to
35:05discuss certain cabinet decision.
35:07Cabinet decision number 116 of 2023.
35:10Then cabinet decision number 49 of 2023.
35:14Then we are going to discuss 142 of
35:162024.
35:19And uh we are going to discuss 56 of
35:222023.
35:24We are going to discuss 35 of 2025.
35:30Then we are going to discuss 37 of 2023.
35:35After this we are going to discuss
35:36certain ministerial decision.
35:38Ministerial decisions.
35:42Ministerial decision number one uh 43 of
35:472023.
35:49Then 1
35:5114 of 2023.
35:56Then 115 of 2023 we are going to discuss
36:01certain FDA
36:04decisions.
36:06FDA decision number three of 2024.
36:11Then we are going to discuss couple of
36:13public clarifications.
36:19Public clarifications are CTP which is
36:22corporate tax public clarification 001
36:25and uh CTP 006.
36:28You must be wondering what is all these
36:30numbers. No need to get stressed. We
36:33already touched upon all these decisions
36:36during our lectures. Uh like I'll give
36:39you a glimpse like what is 116 of 2023.
36:41116 of 2023 spoke about 375,000 dham
36:46zero tax about 3 375,000 dham uh profit
36:509%age tax then 49 of 2023 we it's
36:54discussed about natural person if you
36:56remember natural person uh getting 1
36:59million business income this is what
37:01discussed in this for 142 of 224 this is
37:04talking about pillar 2 means 15%age tax
37:08who will pay M& €750 million euro and
37:12all those things and uh 56 of 2023 and
37:1635 of 2025. These two together is
37:19talking about nexus.
37:23Nexus. If a foreign company has uh
37:26presence in UAE through real estate then
37:29that is considered as Nexus. Then
37:32cabinet edition number 37
37:35of 2023.
37:3737 of 2023 is talking about
37:42qualifying
37:45public benefit entity which we discussed
37:48today.
37:51Then comes
37:54ministerial decision. Ministerial
37:56decision number 43 of 2023 which was the
37:58first ministerial decision. This explain
38:01who is accept ex who does not require to
38:06register for corporate tax purpose
38:08registration exception. Then ministerial
38:11decision 114 of 2023 this is explaining
38:14about accounting
38:17standards if related thing who need to
38:20follow which accounting standard.
38:22Ministry decision 115 of 2023 which we
38:25discussed today. It is talking about
38:27pension fund.
38:30FTA decision number three of 2024 give a
38:33decision on the corporate tax
38:38registration deadline
38:41and there are two public clarification.
38:43This public clarification CTP 001 is for
38:46the registration deadline
38:50and 007 when uh sorry 006
38:56when
38:57uh business got penalty of 10,000 dham
39:00for late registration. FDA told that if
39:02you file within 7 months the penalty
39:04will be waved off. There was a public
39:06clarification on this also. So this is
39:08on the penalty and we will discuss
39:11couple of guides also
39:14guides on natural person. There is a
39:17guide
39:25this also we will discuss in next
39:27session. So what we are trying to do
39:30with the in the next session which is
39:32very important that we have discussed in
39:35previous or including this six chapters
39:38about so many things we referred so many
39:40law decisions clarification all this
39:43thing we are going to put it into a
39:45framework and give an idea to you that
39:47how to read when any uh anything you
39:50want to refer from the corporate tax how
39:52to read. So see you in the next session
39:54until then bye-bye.

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