GTL Summary:

This article establishes the foundational principle for tax deductions. An expense is deductible if incurred 'wholly and exclusively' for the Taxable Person’s business and is not capital in nature. It explicitly disallows deductions for expenditure related to deriving Exempt Income and for non-business losses. For expenditure with a dual purpose (business and non-business), the rules permit a deduction for any identifiable business portion. For unidentifiable portions, an appropriate proportion may be deducted based on a fair and reasonable allocation, reflecting the specific facts and circumstances of the business and the expenditure incurred.

Document Type: Tax Law Article
Law: CIT (FDL No 47 of 2022, as amended)
Article Number: 28
Country: 🇦🇪 UAE
Location: Chapter 9 - Deductions
Order: 28
Last updated at: 2025-11-04 11:19:40 UTC

Chapter 9 - Deductions

Article 28 - Deductible Expenditure

[GTL Notes]

  1. Expenditure incurred wholly and exclusively for the purposes of the Taxable Person's Business that is not capital in nature shall be deductible in the Tax Period in which it is incurred, subject to the provisions of this Decree-Law.

  2. For the purposes of calculating the Taxable Income for a Tax Period, no deduction is allowed for the following:

    1. Expenditure not incurred for the purposes of the Taxable Person's Business.

    2. Expenditure incurred in deriving Exempt Income.

    3. Losses not connected with or arising out of the Taxable Person's Business.

    4. Such other expenditure as may be specified in a decision issued by the Cabinet at the suggestion of the Minister.

  3. If expenditure is incurred for more than one purpose, a deduction shall be allowed for:

    1. Any identifiable part or proportion of the expenditure incurred wholly and exclusively for the purposes of deriving Taxable Income.

    2. An appropriate proportion of any unidentifiable part or proportion of the expenditure incurred for the purposes of deriving Taxable Income that has been determined on a fair and reasonable basis, having regard to the relevant facts and circumstances of the Taxable Person's Business.

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