Article 14 incorporates key administrative provisions of Federal Decree-Law No. 47 of 2022 (Corporate Tax Law) into the Top-up Tax framework, including the General Anti-abuse Rule (GAAR), record-keeping requirements, and assessment procedures. It provides a significant transitional relief: no penalties or sanctions will apply for filings before June 2028 (for years starting on/before Dec 2026) provided the MNE Group took reasonable measures for compliance. This 'soft-landing' period acknowledges the complexity of the new rules and supports taxpayers during the initial implementation years.
Article 14 - Applicability of Certain Provisions of Corporate Tax Law
14.1 The following provisions of Federal Decree-Law No. 47 of 2022 referred to above shall apply to this Decision: