Reconciling Participation Exemptions: UAE Corporate Tax vs. Pillar Two Framework

UAE Corporate Tax regime for foreign dividends and capital gains

Under Article 23 of the UAE Corporate Tax Law dividends and capital gains from Qualifying Participations are exempt from corporate tax. A qualifying Participation requires:

• Minimum ownership, entitlement to profits and liquidation proceeds condition: ownership at least 5% ownership, and same share in dividends distribution and liquidations proceeds. This condition could be disregarded ‘where the aggregated acquisition cost of the ownership interests … is equal to or exceeds AED 4,000,000 (four million dirhams)’.[1] The percentage to apply the domestic participation exemption is the same as in the Netherlands and France, for example, but, as will be shown below it is lower than in Pillar Two framework.
• A minimum 12-month holding period. This condition can be met even if the ownership interest has been held for less than 12 months at the time the income (e.g., dividends) is recognized, provided there is a documented intent to hold the interest for at least 12 months. However, if this intention is not ultimately realized, a clawback applies, meaning the income previously exempted becomes taxable in the period of disposal.
• Subject to tax condition requires that a foreign subsidiary must be subject to Corporate Tax in its country of residence at a rate of at least 9%.[2] If a Participation is resident in a jurisdiction that levies a corporate tax of a similar character to the UAE, at a statutory tax rate of at least 9%, the subject to tax test is met.[3]
• Under assets structure condition, a Participating Interest does not qualify for the Participation Exemption if more than 50% of the Participation’s direct and indirect assets consist of ownership interests or entitlements that by themselves would not qualify for the Participation Exemption regime if held directly by the Taxable Person.[4] This means that if more than half of the Participation’s direct and indirect asset base is made up of such assets, the Participation Exemption would not apply.

This test is intended to prevent potential abuse whereby significant non-qualifying Participations are held through an intermediary entity in order to nonetheless benefit from the Participation Exemption in respect of the intermediary’s income (i.e. income which would not otherwise qualify for the Participation Exemption).[5]

[1] Ministerial Decision No. 302 of 10 December 2024, Article 8.

[2] Corporate Tax Law, Article 23(2)(b).

[3] Guide No. CTGEXI1, Sec. 5.5.2.

[4] Corporate Tax Law, Article 23(2)(d).

[5] Guide No. CTGEXI1, Sec. 5.8.

Dividends and capital gains under Pillar Two

Under the UAE DMTT Rules, a Constituent Entity’s Financial Accounting Net Income or Loss (FINAL) should be adjusted for Excluded Dividends and Excluded Equity Gain or Loss.[1]

[1] Article 3.2.1, paragraphs (b) and (c).

Excluded Dividends under Pillar 2

Excluded Dividends means ‘dividends or other distributions received or accrued in respect of an Ownership Interest, except for:

• a Short-term Portfolio Shareholding, and
• an Ownership Interest in an Investment Entity that is subject to an election under Article 7.4’.[1]

Short-term Portfolio Shareholding means a ‘Portfolio Shareholding that has been economically held by the Constituent Entity that receives or accrues the dividends or other distributions for less than one year at the date of the distribution’, where Portfolio Shareholding means ‘Ownership Interests in an Entity that are held by the MNE Group and that carry rights to less than 10% of the profits, capital, reserves, or voting rights of that Entity at the date of the distribution or disposition, or in the case of fair value movements, at the end of the Fiscal Year’.[2]

Combining these definitions, comment 1:36 of OECD Consolidated Commentary[3] states that ‘Excluded Dividends are dividends or other distributions paid on shares or other equity interests where:

• the MNE Group holds 10% or more of the Ownership Interests in the issuer or
• the Constituent Entity has held full economic ownership of the Ownership Interest for a period of 12 months or more’.

Comment 1:38 reinstates this in the form of the table:

The definitions above indicate that the 10% ownership threshold is determined at the MNE Group level. Accordingly, if one Constituent Entity holds 7% and another holds 3% in the same Ownership Interest, the threshold is considered met. In such cases, the duration of holding is irrelevant for both entities. However, where the Group's aggregate holding is less than 10%, the 365-day holding period test applies individually to each Constituent Entity.

Comment 3:44 clarifies: ‘Unlike the 10% threshold test, the ownership period requirement applies on a Constituent Entity-by-Constituent Entity basis, which means that an intra-group transfer of shares would be considered as an interruption of the holding period’. This means that the period during which one Constituent Entity holds an Ownership Interest does not count towards satisfying the holding period requirement when that interest is subsequently transferred to another Constituent Entity. The 365-day clock effectively resets upon such an intra-group transfer.

A similar approach is adopted under UAE Corporate Tax Law in the application of the Participation Exemption, where:

• Article 3(1)(b) of Cabinet Decision No. 302 of 2024 provides that, for the purpose of determining whether a Taxable Person holds a 5% Participating Interest, the ownership interests held by members of the same Qualifying Group shall be aggregated with those of the Taxable Person. Specifically, the Decision states that ‘ownership interests in the same juridical person held by members of a Qualifying Group… in which the Taxable Person is a member shall be aggregated with those of the Taxable Person’.
• However, the legislation does not provide a similar aggregation rule with respect to the minimum holding period. Consequently, a transfer of a Participating Interest from one member of a Qualifying Group to another is treated as an interruption of the holding period. The transferee must independently satisfy the 12-month uninterrupted holding condition, and the prior holding period of the transferor does not carry over.

[1] UAE DMTT Rules, Article 18.1.

[2] Ibid.

[3] OECD (2025), Tax Challenges Arising from the Digitalisation of the Economy – Consolidated Commentary to the Global Anti-Base Erosion Model Rules (2025): Inclusive Framework on BEPS, OECD/G20 Base Erosion and Profit Shifting Project, OECD Publishing, Paris, https://doi.org/10.1787/a551b351-en.

Excluded capital gains under DMTT and Corporate Tax

Article 18.1(a) of DMTT Rules defines “Excluded Equity Gain or Loss” as ‘the gain, profit or loss included in the Financial Accounting Net Income or Loss of the Constituent Entity arising from gains and losses from changes in fair value of an Ownership Interest’. Clause (c) also excludes ‘gains and losses from disposition of an Ownership Interest’.

Both clauses disqualify “Portfolio Shareholding” from this exemption. Portfolio Shareholding means ‘Ownership Interests in an Entity that are held by the MNE Group and that carry rights to less than 10% of the profits, capital, reserves, or voting rights of that Entity at the date of the distribution or disposition, or in the case of fair value movements, at the end of the Fiscal Year’.

So, under the DMTT Rules, the 10% ownership threshold is the primary condition for excluding equity gains and losses from the GloBE income base. No minimum holding period is required for the exclusion of capital gains, whether arising from disposal or fair value movements, once the 10% threshold is met. However, for dividends, a 365-day minimum holding period applies where the 10% threshold is not met. Accordingly:

• Where the MNE Group holds 10% or more in an entity, capital gains (from revaluation or disposal) and dividends are both excluded from GloBE income regardless of the holding period.
• Where the Group holds less than 10%, the interest is treated as a Portfolio Shareholding. In such cases:
  • Capital gains are never eligible for exclusion, regardless of the holding period.
  • Dividends may still qualify for exclusion, provided the shares have been held for more than 365 days.

This distinction reflects the GloBE framework’s policy of allowing favorable treatment for long-term dividend income, even for smaller shareholdings, while reserving capital gain exclusions exclusively for significant ownership interests.

The first notable discrepancy between the DMTT Exclusion and the domestic participation exemption lies in the absence of a holding period requirement for the exclusion of capital gains.[1] Akin to the dividend exclusion the percentage of shareholding is higher than domestic one.

Commentary 3.55 to the GloBE Rules provides a summary table to illustrate that only non-portfolio shareholdings qualify for the Excluded Equity Gains and Losses treatment. Portfolio shareholdings, by contrast, remain fully includable in GloBE income, regardless of how long they are held:

[1] Comment 3:56

No alternative threshold to the 10% test under Pillar Two/DMTT

As said above, under the UAE Corporate Tax regime, the participation exemption may still apply even where the ownership percentage falls below the 5% threshold provided the acquisition cost of the Participating Interest equals or exceeds AED 4 million. This alternative threshold provides flexibility for taxpayers who hold economically significant but non-controlling stakes in other entities.

In contrast, the Pillar Two framework, including the UAE DMTT rules, contains no similar acquisition-cost-based exemption. Instead, the rules apply a strict 10% ownership threshold for determining whether dividends or capital gains qualify as Excluded Dividends or Excluded Equity Gains and Losses. There is no allowance for substituting the percentage requirement with a monetary value of investment. As a result, an investment that qualifies for exemption under the UAE Corporate Tax Law may fail to qualify under DMTT if the 10% ownership condition is not met.

Intention vs. strict duration

Under the Pillar Two framework, the 365-day holding period is applied as a strict factual test based on the actual duration of ownership at the time the dividends or distributions are received or accrued. Specifically, the rules provide that Excluded Dividends do not include dividends received from a Portfolio Shareholding (i.e., less than 10% interest) that has been economically held for less than one year at the time of the distribution. The Commentary to the GloBE Model Rules (Commentary 3:36) reinforces that intention to hold is not a relevant factor; only the actual holding period counts. This rigid approach ensures certainty but offers no relief based on the taxpayer’s intention, nor does it allow for reassessment once the one-year holding threshold is reached after the dividends or other distributions have been accrued or received.

By contrast, under the UAE Corporate Tax Law, the 365-day holding condition in Article 23(2)(b) is applied more flexibly. The exemption for dividends may apply even if the 12-month period has not yet been completed at the time the dividend is received, provided the taxable person can demonstrate an intention to hold the Participating Interest for at least 12 months. This accommodates commercial realities where dividends may be received shortly after acquisition of the shares. However, if the intention is not ultimately realized, a clawback provision applies, requiring the taxpayer to reverse the exemption and include the previously exempt income in the taxable income of the disposal year. This distinction could be seen in Example 22 of the Corporate Tax Exempt Income Guide No. CTGEXI1.

Holding period test when multiple ownership interests are held

A Taxable Person may hold multiple ownership interests in the same juridical person, either acquired at different times or consisting of different share classes (e.g., ordinary and preferred shares). These interests may not all be held for the same duration. This raises the question: How should the 12-month holding period condition be assessed when part of the interest is disposed of?

Under the UAE Corporate Tax Law, this situation is addressed in Section 5.3.2 of the FTA’s Guide No. CTGEXI1. The FTA clarifies that ‘once the conditions of the Participation Exemption are met, the ownership interests form a single Participation. Accordingly, where part of a Participating Interest is disposed of, the holding period condition is to be tested in respect of the Participation as a whole and not each ownership interest individually’.

This principle is illustrated in Example 7 of the Guide where Company A (a company incorporated and resident in the UAE) purchases and sells shares of Company Z (a company incorporated and managed outside the UAE) as follows:

In this case, even though the Preferred Shares sold have been held for only 3 months, the holding period test is satisfied based on Company A’s overall ownership interest in Company Z, which is over 12 months.

In contrast, the Pillar Two framework, as adopted in the UAE DMTT Rules, applies a more granular and rigid approach. OECD Commentary 3:43 clarifies that the 12-month test is applied at the class level:

• ‘Whether the Constituent Entity has economically held the Portfolio Shareholding for one year is tested on the date of the distribution of the dividends. Fluctuations of the Ownership Interest held in an Entity should be taken into account for that purpose. In this respect, the disposition of an Ownership Interest in a particular class of shares is deemed to be a disposition of the most recently acquired Ownership Interests of the same class that were acquired the last, for simplification purposes’.
• ‘For that purpose, a class of shares means the shares issued by the distributing entity that carry the same rights such that they are inter-changeable with each other. For example, an Entity that has issued common shares with rights to profits and net assets upon dissolution and preferred shares that are entitled to a dividend of EUR 100 each year and redeemable in ten years for EUR 2 000 has two classes of stock. Accordingly, dispositions of preferred shares do not affect the determination of the holding period of the common shares’.

Commentary 3:44 confirms that the 365 days test ‘applies … in respect of the same class of shares such that the dividends received or accrued in respect of the same class of shares that were held for a year or more are exempted, whereas other dividends are not’. This appears to be different for the Corporate Tax for which:

• ‘once the conditions of the Participation Exemption are met, the ownership interests form a single Participation’;
• where part of a Participating Interest is disposed of, the holding period condition is to be tested in respect of the Participation as a whole and not each ownership interest individually’.

This divergence again underscores that qualifying under one regime does not guarantee exemption under the other. Taxpayers should maintain detailed records of acquisition dates, share classes, and legal holder information for each entity to accurately assess compliance under Pillar Two frameworks.

Absence of Subject-to-Tax and Asset Composition Tests under Pillar Two/DMTT

In addition to the ownership threshold and holding period, the Corporate Tax Law imposes:

• The subject to tax condition (Article 23(2)(b)), which requires that the foreign Participation be resident in a jurisdiction that levies corporate tax of a similar character to that of the UAE at a statutory rate of at least 9%, and
• The asset composition condition (Article 23(2)(d)), which disqualifies a Participating Interest from the exemption if more than 50% of its direct and indirect assets consist of ownership interests or entitlements that would not themselves qualify for the participation exemption if held directly.

In contrast, the Pillar Two framework, as implemented under the UAE DMTT rules, imposes no equivalent tests. The qualification of dividends or capital gains for exclusion under Articles 18.1 of the DMTT Rules depends solely on the shareholding percentage (≥10%) and, in the case of dividends from portfolio holdings, the duration of ownership (≥12 months). There is no subject-to-tax requirement, nor is there any test based on the underlying asset composition of the entity in which the shares are held.

This simplified and more mechanical approach under Pillar Two is intended to support global consistency and administrative feasibility, but it may result in scenarios where income excluded under DMTT would not qualify for exemption under UAE Corporate Tax Law due to failing one of these additional domestic conditions.

Difference in Coverage

Article 23(5) of Corporate Tax Law sets out the scope for domestic participation exemption: ‘the following income shall not be taken into account in determining Taxable Income:

1. Dividends and other profit distributions
2. Gains or losses on the transfer, sale, or other disposition of a Participating Interest (or part thereof) derived after expiry of the 365 days period of the interrupted holding;
3. Foreign exchange gains or losses in relation to a Participating Interest.
4. Impairment gains or losses in relation to a Participating Interest’.

This list is exhaustive, and does not include unrealized fair value gains or losses recognized through profit or loss, such as those arising under IFRS 9 when a Participating Interest is measured at FVTPL (Fair Value through Profit or Loss). As a result, unrealized gains from remeasurement of equity investments to fair value (even if they relate to a qualifying Participating Interest) may remain within the scope of taxable income under the Corporate Tax Law unless and until they are realized via disposal.

Clause (d) of Article 23(5) of Corporate Tax Law refers to “impairment gains or losses”. This exemption does not apply to equity investments that are measured at fair value through profit or loss (FVTPL) or fair value through other comprehensive income (FVOCI). Under IFRS 9, such instruments are remeasured periodically at fair value, and the resulting gains or losses are treated as changes in market value, not impairments.

The concept of impairment is typically relevant when equity investments are accounted for at cost. In such cases, if there is objective evidence that the investment may be impaired, the investor is required to test for impairment in accordance with IAS 36 “Impairment of Assets.” If the recoverable amount of the investment falls below its carrying amount (cost), an impairment loss must be recognized.

This treatment is illustrated in Example 23 of the FTA’s Exempt Income Guide No. CTGEXI1, where an impairment loss is first deducted, reducing the investment’s book value. Upon subsequent disposal at a higher price, the resulting capital gain includes both a reversal of the impairment and a residual capital gain. Only the portion representing the reversal of the impairment loss may qualify for exemption under Article 23(5)(d) as an “impairment gain,” provided the investment qualifies as a Participating Interest at the time of disposal.

In contrast, Article 18.1 of DMTT Rules defines “Excluded Equity Gain or Loss” as ‘the gain, profit or loss included in the Financial Accounting Net Income or Loss of the Constituent Entity arising from:

• gains and losses from changes in fair value of an Ownership Interest, except for a Portfolio Shareholding;
• profit or loss in respect of an Ownership Interest included under the equity method of accounting; and
• gains and losses from disposition of an Ownership Interest, except for a disposition of a Portfolio Shareholding’.

Here, paragraph (a) clearly captures unrealized fair value changes, excluding them from the GloBE income base, provided the Ownership Interest is not a Portfolio Shareholding (typically <10%). This rule is notably broader than Article 23(5) of the Corporate Tax Law, which does not explicitly exclude such fair value gains.

So, while both regimes aim to prevent taxation of income from substantial shareholdings, the UAE domestic participation exemption under Article 23 does not explicitly exclude revaluation gains unless they fall under “impairment reversals” or are realized through disposal. In contrast, the DMTT rules treat unrealized gains as excluded, reflecting the Pillar Two principle of neutrality for long-term strategic investments irrespective of accounting volatility.

As such, taxpayers applying IFRS 9 with fair value treatment for equity instruments qualifying as Participating Interests should exercise caution: unless those fair value gains fall within one of the explicit categories in Article 23(5), they may be subject to UAE Corporate Tax, even though the same amounts would be excluded for DMTT purposes.

Additionally, as clarified in Section 6.2 of the FTA’s Exempt Income Guide No. CTGEXI1, the gain or loss on the disposal of a Participating Interest is computed based on the book value at the time of disposal under the applicable accounting standards. This means that any previously recognized revaluation gains (e.g., through FVTPL) are embedded in the book value and thus reduce the capital gain eligible for exemption under Article 23(5)(b). These gains are not separately exempted, having already passed through taxable profit in prior periods.

Therefore, the DMTT rules exclude revaluation gains prospectively, whereas UAE Corporate Tax Law only exempts capital gains to the extent they are realized at the time of disposal, and only the difference between the disposal proceeds and the updated book value explicitly qualifies. This may lead to a potential timing mismatch and double inclusion.

Example

The entity is UAE-based, applies IFRS, and consolidates its financials. The equity stake is a foreign Participating Interest qualifying for Article 23(2) of Corporate Tax Law. The equity is measured at FVTPL. The entity is subject to both UAE Corporate Tax and Pillar Two/DMTT.

As illustrated in the table above, for UAE Corporate Tax:

• In Year 2, the AED 300,000 gain is taxed (because not explicitly covered by any clause of Art. 23(5)).
• In Year 3, the AED 50,000 capital gain (difference between sale proceeds and book value) is exempt.

Total gain taxed calculated as difference between this two equals AED 50,000. Effectively, this leads to partial exemption of capital gains, not full.

• In DMTT, the full exemption applies:
• In Year 2, in contrast to domestic exemption, the AED 300,000 is excluded under 18.1(a) of the DMTT Rules.
• In Year 3, the AED 50,000 is also excluded under 18.1(c).

Total gain excluded equals AED 350,000, and reflects full exemption of equity gain, aligned with GloBE’s neutrality principle.

Notably, the current legislation allows the FTA or the Minister a degree of interpretative discretion when applying Article 23(5)(b) of the Corporate Tax Law. While the provision explicitly refers to “gains or losses on the transfer, sale, or other disposition of a Participating Interest,” one could argue that unrealised revaluation gains might also be encompassed if they are considered as becoming realised at the moment of transfer. Under this view, previously recognised revaluation gains could be treated as part of the overall “gain on disposal,” and therefore indirectly fall within the scope of the exemption.

However, there is currently no indication that the FTA is inclined to adopt such a broad or purposive interpretation. On the contrary, Example 22 of the Exempt Income Guide No. CTGEXI1 suggests a narrower, more literal approach:

‘Example 22: Revaluation of Participating Interest (unrealised gain)

Company A (a company incorporated and resident in the UAE) acquired shares in Company F (a company incorporated and managed outside the UAE which is a Participation Interest) for GBP 1,000. At the time of purchase, the value of GBP 1 was equal to AED 4.5, and so Company A recorded the shares at AED 4,500 in its Financial Statements. At the end of the following year Company A revalued Company F’s shares in its Financial Statements to their market price.

At that time, the market price of Company F shares has increased to GBP 2,000, and the value of GBP 1 is AED 5. Accordingly, in Company A’s Financial Statements, the value of the Participating Interest in Company F is increased from AED 4,500 to AED 10,000. Out of total revaluation gain of AED 5,500, a gain of AED 1,000 is attributable solely to foreign currency fluctuations which is exempt from Corporate Tax under the Participation Exemption.’

The example’s explicit separation of the foreign exchange gain (AED 1,000) from the remaining revaluation gain (AED 4,500), and the fact that only the FX component was exempted, indicates that Article 23(5) does not extend to revaluation gains in general. This suggests that, in the FTA’s current interpretation, there is no legal basis in Article 23(5) for exempting unrealised revaluation gains, other than those explicitly attributable to:

• Foreign exchange movements (under clause (c)), or
• Impairment reversals (under clause (d)), or
• Realised capital gains on disposal (under clause (b)).

Therefore, unless or until broader interpretative guidance is issued, taxpayers should consider conservative approach, i.e. to proceed on the basis that unrealised revaluation gains remain within the scope of taxable income under the UAE Corporate Tax Law.

Expenditure related to Exempt Income

According to Article 11(1) of Ministerial Decision No. 302 of 10 December 2024, under the UAE Corporate Tax regime, expenses related to income qualifying for the Participation Exemption are not deductible, with the exception of interest expenditure.

For the purpose of Top-up Tax base, the expenses related to Excluded Dividends are deductible. According to Comment 3:45, ‘although local tax rules typically disallow deductions for expenses associated with income that is excluded from taxable income, for simplicity, the GloBE Rules do not disallow expenses related to Excluded Dividends …’.

Absence of two-year restriction in Pillar Two / DMTT Framework

Under Article 23(9) of the Corporate Tax Law, the Participation Exemption does not apply for a period of two years following the acquisition of a Participating Interest in specific cases designed to prevent abusive restructurings. These include situations where:

• The Participating Interest is acquired in exchange for a non-qualifying ownership interest;
• The acquisition occurs as part of a tax-neutral intragroup transfer within a Qualifying Group under Article 26; or
• The transfer is made under a Business Restructuring Relief arrangement pursuant to Article 27.

During this two-year deferral period, any income derived from the newly acquired Participation (such as dividends or capital gains) is not eligible for exemption, even if all other conditions are met. This rule reflects a domestic anti-avoidance safeguard aimed at ensuring that the exemption is granted only where genuine economic ownership of qualifying interests exists over a sufficient period.

By contrast, the Pillar Two framework, including the UAE's DMTT rules, contains no equivalent two-year holding restriction. There is no rule delaying the application of the exclusion following restructurings, intragroup transfers, or exchanges of assets. Instead, the Pillar Two rules focus on objective, current facts at the time of the distribution or gain.

The only comparable rule is found in Commentary 3:44, which provides that intragroup transfers reset the holding period unless they qualify as a GloBE Reorganisation. However, this rule does not represent a divergence from the UAE Corporate Tax regime in cases where:

• a Taxable Person exchanges an ownership interest in one juridical person for that in another juridical person, and
• where this exchange does not give rise to Taxable Income, due to the application of Business Restructuring Relief.

In these cases, the ownership of the two interests is treated as a single continuous ownership (not two separate ownership periods) provided that both qualify as Participating Interests. This means the period of ownership can look through a qualifying business restructuring.[1]

Accordingly, income excluded under DMTT may be taxable under UAE Corporate Tax if it arises within the two-year restriction period, and vice versa. Taxpayers should be mindful of this divergence when structuring reorganisations or implementing participation-based holding strategies.

[1] Article 4 of Ministerial Decision No. 302 of 10 December 2024, Sec. 5.3.3 of the FTA’s Guide No. CTGEXI1.

Conclusion

While both the UAE Corporate Tax regime and the UAE DMTT Rules (aligned with the OECD Pillar Two framework) aim to eliminate taxation on income derived from substantial shareholdings, their respective technical criteria, ownership thresholds, and timing mechanisms diverge significantly. As a result, mismatches may arise in either direction. For example, a capital gain on a 6% shareholding held for over a year may be exempt under the UAE Corporate Tax participation exemption, but fully included in GloBE income under the DMTT Rules as it fails the 10% threshold for equity gain exclusion. Conversely, unrealized fair value gains recognized through FVTPL accounting may be taxable under UAE Corporate Tax, yet excluded from GloBE income under Article 18.1(a) of the DMTT Rules. These structural differences can lead to partial or misaligned taxation, requiring taxpayers to carefully assess eligibility under both regimes and remain alert to the risk of timing mismatches or economic double inclusion.

A summary of key differences between UAE Corporate Tax and DMTT rules is presented in the table below:

The disclaimer

Pursuant to the MoF’s press-release issued on 19 May 2023 “a number of posts circulating on social media and other platforms that are issued by private parties, contain inaccurate and unreliable interpretations and analyses of Corporate Tax”.

The Ministry issued a reminder that official sources of information on Federal Taxes in the UAE are the MoF and FTA only. Therefore, analyses that are not based on official publications by the MoF and FTA, or have not been commissioned by them, are unreliable and may contain misleading interpretations of the law. See the full press release here.

You should factor this in when dealing with this article as well. It is not commissioned by the MoF or FTA. The interpretation, conclusions, proposals, surmises, guesswork, etc., it comprises have the status of the author’s opinion only. Furthermore, it is not legal or tax advice. Like any human job, it may contain inaccuracies and mistakes that I have tried my best to avoid. If you find any inaccuracies or errors, please let me know so that I can make corrections.