Under Article 35 of the Corporate Tax Law, this clarification states that common ownership or control of entities solely through a UAE Federal or Local Government does not, by itself, classify them as Related Parties. Consequently, transactions between such entities are not subject to the arm's length principle outlined in Article 34, nor are they required to maintain transfer pricing documentation for these transactions. It emphasizes, however, that entities within the same specific government-owned group structure (e.g., a government-owned holding company and its direct subsidiary) remain Related Parties to each other.
CTP002
Corporate Tax Public Clarification
The definition of 'Related Parties' where there is a common ownership and/or Control through a Government Entity
Issue
Corporate Tax in the UAE is regulated by Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses, and its amendments ("Corporate Tax Law").
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