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July 30, 2026
Article 6 specifies the tax treatment for Government Controlled Entities (GCEs). While generally exempt, a GCE becomes subject to Corporate Tax if it undertakes any Business or Business Activity that falls outside its 'Mandated Activities'. Such non-mandated activities are treated as an independent business, requiring the GCE to maintain separate financial statements and calculate Taxable Income for that business independently. Crucially, transactions between the GCE's taxable, non-mandated business and its exempt Mandated Activities are deemed Related Party transactions. These transactions must adhere to the arm's length principle outlined in Article 34 of the law.
Chapter 3 - Exempt Person
Article 6 - Government Controlled Entity
[GTL Notes]
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