UAE Law and Practice Contributed by: Ildar Yuvakaev, Ruslan Akhmetov, Olga Serova and Daiana Ubushaeva, Consigliere Group
private investors remain outside the scope of the VAT regime. Pillar Two The UAE has been implementing the OECD Pillar Two rules from 2025. Multinational enterprise groups with annual consolidated revenue of at least EUR750 mil - lion in at least two of the four financial years immedi - ately preceding the relevant financial year, are subject to a domestic minimum top-up tax. Partnerships Incorporated partnerships are subject to corporate tax as companies. Unincorporated partnerships are gen - erally treated as fiscally transparent, with tax liabilities arising at the partner level. The unincorporated partnership regime may also apply to foundations established in the Abu Dhabi Global Market (ADGM) and Dubai International Financial Centre (DIFC). Where a family foundation meets the conditions specified in Article 17 (1) of the Corporate Tax Law, it may benefit from tax-neutral treatment. Investment funds Certain qualifying investment funds and real estate investment trusts (REITs) may also benefit from a 0% corporate tax rate or tax-transparent treatment, sub - ject to the statutory conditions. Single family offices Family offices generally do not qualify for tax-trans - parent treatment under Article 17 of the Corporate Tax Law. Where established as juridical persons, they are treated as resident taxable persons and are subject to corporate tax. Where a family office is a free zone person, it may benefit from a 0% corporate tax rate on qualifying income – eg, wealth and investment management ser - vices, or fund management services – that are subject to the regulatory oversight of a competent authority in the UAE. 1.2 Exemptions Individuals Transfers between close family members may ben - efit from exemptions from property transfer fees. For
example, in Dubai, qualifying gifts of property between spouses or other first-degree relatives (mother, father or children), or to companies may be subject to a reduced transfer fee of 0.125%, subject to applicable minimum fees. Participation Exemption The UAE Corporate Tax Law also provides a partici - pation exemption for qualifying dividends and capital gains derived from qualifying shareholdings, subject to the conditions prescribed by the Corporate Tax Law. 1.3 Income Tax Planning The UAE’s main tax planning opportunities arise from the absence of personal income tax, capital gains tax, inheritance tax, gift tax and wealth tax. Planning focuses on maintaining genuine UAE tax residence and ensuring income remains outside UAE corporate tax where possible. Family foundations, trusts and QFZP structures remain important tools for succession and wealth planning, subject to substance requirements and anti-abuse rules. The participation exemption may allow qualifying holding structures to receive dividends and realise certain capital gains without paying UAE corporate tax. The UAE treaty network may improve cross-border efficiency, although controlled foreign corporation (CFC), attribution, citizenship-based taxation rules and Pillar Two considerations remain relevant. 1.4 Pre-Immigration and Exit Planning The UAE does not impose a separate personal exit tax, as stated in 1.1. Tax Regimes . Pre-immigration planning is therefore mainly driven by the individual’s former jurisdiction and by the assets that remain outside the UAE. Some jurisdictions do not rely only on physical presence or current tax resi - dence. They may continue to tax certain persons or assets by reference to citizenship, domicile, the loca - tion of assets, the residence of heirs or beneficiaries,
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