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In this article we address a few of the issues in the recent Decisions of the UAE’s Cabinet. Read more in the article of Andrey Nikonov, Senior Partner, and Maria Nikonova, Partner.

A distribution company is incorporated in a designated zone in the UAE. Its facilities are located in the designated zone from where its employees buy the goods in China, resell them to Indian customers, and arrange shipment of the bought goods to an Indian customer for subsequent resale. The goods do not enter the UAE and its free zone (designated zones). On 27 October 2023, the MoF issued Decision No. 265, replacing Decision  No. 139 with a list of Qualifying and Excluded Activities. The rules concerning distribution from or in a designated zone haven’t been substantially changed. Does such distribution of goods outside of the UAE qualify for 0% Corporate Income Tax (CIT)? Read more in the article of Andrey Nikonov and Maria Nikonova.

The UAE’s FTA issued Transfer Pricing Guide No. CTGTP1 this week. The FTA sets forth the following hierarchical algorithm... Read more in the article of Andrey Nikonov.

Concept of POEM in the UAE Corporate Taxation. Article 11(3)(b) of the Corporate Tax Law deems as a tax resident ‘a juridical person that is incorporated or otherwise established or recognized under the applicable legislation of a foreign jurisdiction that is effectively managed and controlled in the State’. Read more in the article of Andrey Nikonov, Senior Partner.

The UAE MoF in Article 2(1)(k) of the Decision No. 139 qualified for 0% Corporate Tax rate ‘Distribution of goods or materials in or from a Designated Zone to a customer that resells such goods or materials, or parts thereof or processes or alters such goods or materials or parts thereof for the purposes of sale or resale’. Read more in the article of Andrey Nikonov.

A holding company is registered in the UAE free zone. It earns dividends and capital gains. Every once in a while, the Company deposits money in interest bearing accounts in UAE and foreign banks. The holding of shares qualifies for a 0% Corporate Tax rate, while interest on deposit in an independent bank does not. In some financial periods, interest added to some occasional non-qualifying income received may increase to 5% of the total revenues or 5,000,000 AED.  The question: is there any option to apply the 0% Corporate Tax rate to interest paid to deposit account holders? 

03.07.2025
Pepeliaev Group and the Administration of Harbin Area in the China (Heilongjiang) Pilot Free Trade Zone have signed an agreement for strategic cooperation
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02.07.2025
Natalia Prisekina has again visited Harbin (PRC) with a business mission
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01.07.2025
Pepeliaev Group has elected a new partner
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