Articles

11.08.2025

Cost of funding in a Permanent Establishment: recognition of notional interest

This case study addresses the application of the Authorised OECD Approach (AOA) to profit attribution for Permanent Establishments (PEs) in the United Arab Emirates. While FTA’s Guide No. CTGTP1 aligns
28.07.2025

The dual thresholds for identifying an MNE Group under Pillar Two: from structure to size

The Pillar Two framework, as adopted in the UAE through the Domestic Minimum Top-Up Tax (DMTT) regime, employs a two-step mechanism to determine whether a group falls within scope. The
21.07.2025

Development of Non-Commercial Property

This case study explores the corporate tax implications under the UAE Corporate Tax Law when a Free Zone-based developer engages in residential property projects located both in the UAE mainland
18.07.2025

Depreciation of investment properties held at fair Value: Ministerial Decision No. 173 of 2025

Today, on 18 July 2025, the UAE Minister of Finance published Ministerial Decision No. 173 dated 23 June 2025 titled “On Depreciation Adjustments for Investment Properties Held at Fair Value.”
14.07.2025

Downward adjustment when no asset or cost is recognized under IFRS

This case study examines the transfer pricing implications of a business transfer between two related parties in the UAE where neither Qualifying Group Relief (QGR) nor Business Restructuring Relief (BRR)
13.07.2025

What’s new in UAE tax: PGP June Digest

We are pleased to present the June 2025 edition of our monthly digest, featuring key tax and regulatory developments across the UAE and the GCC region. This month’s spotlight is
30.06.2025

Navigating Corporate Tax in the UAE? Avoid These Common Pitfalls

The introduction of UAE Corporate Tax has transformed the compliance landscape for Free Zone and mainland companies alike. Yet, many businesses continue to face unexpected risks — simply because of
17.06.2025

What’s new in UAE tax: PGP May Digest

This Month’s Spotlight: The UAE Guide on Family Foundations This month, we focus on the recently issued Guide on Family Foundations in the UAE — a valuable instrument offering fiscal transparency for foundations
12.06.2025

Clarifying “Similar Entities”: Insights from the Family Foundations Guide (May 2025)

In our earlier research, we explored how the concept of “similar entities” under the UAE Corporate Tax Law could be interpreted, particularly for structures that are not explicitly labeled as “trusts”