This Decision details the implementing rules for the Participation Exemption (Article 23) and the Foreign Permanent Establishment Exemption (Article 24) under UAE's Corporate Tax Law (Federal Decree-Law No. 47 of 2022). Key conditions for the Participation Exemption include the 'subject to tax' test, which requires a minimum 9% tax rate on the participation's income, or an alternative AED 4 million minimum acquisition cost. The decision also provides specific rules for holding companies and clarifies the calculation and deductibility of liquidation losses. Crucially, this Decision repeals Ministerial Decision No. 116 of 2023 for tax periods commencing on or after 1 January 2025.