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May 15, 2026

This Decision outlines conditions for Private Pension Funds and Private Social Security Funds to apply for Corporate Tax exemption under Article 4 of the Corporate Tax Law. Key criteria include having an asset pool exclusively for financing pension or End of Service benefits, deriving income from restricted sources like investments, and appointing an Auditor. It also allows an employer's contributions to a private pension fund to be a deductible expense for Corporate Tax purposes, limited to a maximum of 15% of the employee's total remuneration for the relevant tax period.

This is not an Official Translation:

Private Pension Funds and Private Social Security Funds for the Purposes of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses

Ministerial Decision No. 115 of 2023

Issued 10 May 2023 – (Effective the day after publishing in the Official Gazette)

[GTL Notes]

The Minister of State for Financial Affairs has decided:

Having reviewed the Constitution,
Federal Law No. 1 of 1972 on the Competencies of Ministries and Powers of the Ministers, and its amendments,
Federal Law No. 7 of 1999 on the Issuance of the Law of Pensions and Social Security, and its amendments,
Federal Decree-Law No. 13 of 2016 on the Establishment of the Federal Tax Authority, and its amendments,
Federal Decree-Law No. 33 of 2021 Regulating Labour Relations, and its amendments,
Federal Decree-Law No. 28 of 2022 on Tax Procedures,
Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses,

Article 1 - Definitions

Words and expressions in this Decision shall have the same meanings specified in the Federal Decree-Law No. 47 of 2022 referred to above ('Corporate Tax Law'), and the following words and expressions shall have the meanings assigned against each, unless the context otherwise requires:

Article 2 - Private Pension Fund

A private pension fund may apply to the Authority to be exempt from Corporate Tax under paragraph (g) of Clause 1 and Clause 3 of Article 4 of the Corporate Tax Law where all of the following conditions are met:

The fund comprises a pool of assets which have been assigned by law or contract as Pension Plan assets or the acquisition of these assets has been financed by or with the use of contributions to a Pension Plan for the exclusive purpose of financing the Pension Plan benefits.
The fund grants Pension Plan Members or Beneficiaries a right or other contractual claim or entitlement, against its assets or earnings.
The income of the fund solely comprises income as specified in Article 4 of this Decision.
The fund must have an Auditor.

Article 3 - Private Social Security Fund

A private social security fund may apply to the Authority to be exempt from Corporate Tax under paragraph (g) of Clause 1 and Clause 3 of Article 4 of the Corporate Tax Law where all of the following conditions are met: