This decision establishes when a non-resident juridical person has a tax nexus in the UAE for Corporate Tax purposes. A nexus is created if the non-resident person earns any income from immovable property located in the State, including from its sale, disposal, letting, or any other form of exploitation. An anti-abuse rule targets the artificial transfer of rights in immovable property to evade tax. Non-resident persons who are determined to have a nexus under these rules are required to register for Corporate Tax with the Federal Tax Authority. The decision is effective from June 1, 2023.