Articles

FOREX gain and losses from remeasurement of cash and bank balances: can the realisation basis be elected?

This case study addresses the treatment of foreign exchange differences on cash and bank balances under the UAE Corporate Tax regime. The question arises from the interaction between the mandatory

Treasury and financing “for its own account” under Ministerial Decision 229 of 2025

This Thursday, the Minister of Finance has published Ministerial Decision (MD) No. 229 of 28 August 2025, which repeals MD No. 265 of 2023 and applies retroactively from 1 June

Applicability of the Beneficial Recipient Requirement for Qualifying Income under Article 3(1)(b) of Cabinet Decision No. 100/ 2023:

Determining the scope of the UAE DMTT for Cayman-BVI Groups managed from the UAE

This case study examines the potential application of the Domestic Minimum Top-up Tax (DMTT) in the United Arab Emirates to a Group structured through entities incorporated in the Cayman Islands,

Qualification of a Commodity as a “Qualifying Commodity” Where Only Cash-Settled Derivatives Are Traded on a Recognised Commodities Exchange

What’s new in UAE tax: PGP July Digest

Dear Colleagues, We are pleased to share with you the July 2025 edition of our monthly digest, highlighting the most relevant tax and regulatory updates across the UAE and broader

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

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

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