For tax periods from 1 January 2025, juridical investors in an exempt Real Estate Investment Trust (REIT) are subject to Corporate Tax on 80% of prorated Immovable Property Income. The clarification distinguishes between a distributing fund," which distributes at least 80% of this income within nine months of its financial year-end, and a "non-distributing fund," affecting when income is taxed. It also covers compliance obligations for REITs and investors, and establishes that a non-resident investor creates a "nexus" in the UAE, which mandates registration for Corporate Tax purposes."
CTP005
Corporate Tax Public Clarification
Taxation of investors in a Real Estate Investment Trust that is exempt from Corporate Tax as a Qualifying Investment Fund
Issue
The Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Business, and its amendments (“Corporate Tax Law”) applies to Tax Periods commencing on or after 1 June 2023.
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