UAE Corporate Tax Advisory

For businesses that have assessed their position and need to put the infrastructure in place, we provide end-to-end implementation support: setting up compliant accounting records, establishing the chart of accounts and cost centre structure and preparing the business for its first return filing. This is a one-time engagement that sets the foundation for ongoing compliance.

We prepare the annual tax computation, identify all available deductions and reliefs, and file the corporate tax return with the FTA within the prescribed statutory deadline. For businesses that are part of a UAE group, we advise on group relief elections, tax loss transfers, and the conditions for forming a tax group under UAE Corporate Tax Law. We also handle corporate tax registration and de-registration, including the coordination required with FTA when entities are wound down or restructured out of a UAE group. In addition, we also provide support in changing the corporate tax period previously allocated by the FTA. Where income has been taxed in another jurisdiction, we handle the foreign tax credit claim and ensure it is properly documented and disclosed.

The 0% corporate tax rate available to free zone entities is not automatic. An entity must qualify as a Qualifying Free Zone Person under various decisions issued by FTA which sets out the substance requirements, the types of income that qualify, and the de minimis threshold for non-qualifying revenue. We carry out this analysis for each financial year, document the position, and advise on what operational or structural changes, if any, are needed to maintain qualifying status. Where the position is uncertain, we advise on the options and the risks before the filing date.

UAE transfer pricing rules follow the OECD BEPS framework. Businesses with related-party transactions and payments to connected person above the prescribed thresholds are required to maintain a master file and local file and submit a disclosure form alongside the corporate tax return. We prepare this documentation, support the benchmarking analysis, and ensure the positions taken in the disclosure are consistent with the return.

Where a transaction or structure raises a question about applicable treatment, we prepare a formal written advisory opinion. This is a document prepared for the client, grounded in the relevant provisions of UAE Corporate Tax Law, the implementing decisions, and the OECD guidance where applicable. It sets out the facts, the technical analysis, the conclusion, and the basis for it. Advisory opinions are used internally for board decisions and relied upon for regulatory filings.

Where a question requires the FTA's view, we prepare and file a private clarification request. This is particularly useful for QFZP positions, group restructuring, and cross-border arrangements where the DTAA interaction is not straightforward. We set out the facts, the technical analysis, and the alternative positions in a format designed to get a substantive FTA response.

When the FTA issues a notice or opens a review, the quality of the response matters. We manage the correspondence, prepare the factual and technical response, and where required, prepare a formal basis of return filing as a defence record. For voluntary disclosures, we prepare the submission and advise on timing and disclosure strategy.

For businesses with UAE and non-UAE operations, we advise on the interaction between UAE corporate tax and the relevant double taxation avoidance agreements, Permanent Establishment and POEM considerations, and the UAE participation exemption for dividends and capital gains. Where restructuring is being considered, we advise on the tax consequences at entry and exit, including qualifying group conditions and the exempt entity analysis. This work is closely coordinated with our UAE Market Entry practice for businesses still in the setup phase.