GTL Summary:

Article 6 specifies the tax treatment for Government Controlled Entities (GCEs). While generally exempt, a GCE becomes subject to Corporate Tax if it undertakes any Business or Business Activity that falls outside its 'Mandated Activities'. Such non-mandated activities are treated as an independent business, requiring the GCE to maintain separate financial statements and calculate Taxable Income for that business independently. Crucially, transactions between the GCE's taxable, non-mandated business and its exempt Mandated Activities are deemed Related Party transactions. These transactions must adhere to the arm's length principle outlined in Article 34 of the law.

Document Type: Tax Law Article
Law: CIT (FDL No 47 of 2022, as amended)
Article Number: 6
Country: 🇦🇪 UAE
Location: Chapter 3 - Exempt Person
Order: 6
Last updated at: 2025-11-04 11:19:40 UTC

Chapter 3 - Exempt Person

Article 6 - Government Controlled Entity

[GTL Notes]

  1. A Government Controlled Entity shall be exempt from Corporate Tax and the provisions of this Decree-Law shall not apply to it.

  2. Notwithstanding Clause 1 of this Article, a Government Controlled Entity shall be subject to the provisions of this Decree-Law if it conducts a Business or Business Activity that is not its Mandated Activities.

  3. Any Business or Business Activity conducted by a Government Controlled Entity that is not its Mandated Activity shall be treated as an independent Business, and the Government Controlled Entity shall keep financial statements for this Business separately from its Mandated Activity.

  4. The Government Controlled Entity shall calculate the Taxable Income for its Business or Business Activity that is not its Mandated Activity independently for each Tax Period, in accordance with the provisions of this Decree-Law.

  5. Transactions between the Business or Business Activity specified in Clause 2 of this Article and the Mandated Activity of the Government Controlled Entity shall be considered Related Party transactions subject to the provisions of Article 34 of this Decree-Law.

←
Previous
Article 5 - Government Entity
Next
Article 7 - Extractive Business
→

Related Documents

Fast-loading version for search engines - Click here for the interactive version