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July 30, 2026
This article provides a safe harbour rule, known as the Investment Manager Exemption, to prevent a non-resident's use of a UAE-based investment manager from creating a Permanent Establishment (PE). An Investment Manager is considered an independent agent, thus not creating a PE for their non-resident client, if several conditions are met. These include being a regulated business, acting in the ordinary course of business, operating independently and at arm's length for due compensation, and not acting as the client's representative for other taxable income. This protects the UAE's status as an investment management hub.
Chapter 4 - Taxable Person and Corporate Tax Base
Article 15 - Investment Manager Exemption
[GTL Notes]
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