Article 14 - Applicability of Certain Provisions of Corporate Tax Law

14.1 The following provisions of Federal Decree-Law No. 47 of 2022 referred to above shall apply to this Decision:

(a)Article 50 - General Anti-abuse Rule.

(b)Article 56 - Record Keeping.

(c)Article 59 - Clarifications.

(d)Article 60 - Assessment of Corporate Tax and Penalties.

14.2 For the purposes of Article 14.1 the following applies:

(a) Reference to a Taxable Person shall include reference to a Constituent Entity and Parent Entity, as applicable.

(b) Reference to Corporate Tax shall include reference to taxes imposed under the provisions of this Decision.

(c) Reference to Tax Period shall include reference to Fiscal Year.

14.3 For purposes of Article 14.1(d), during the Fiscal Year beginning on or before 31 December 2026 but not including a Fiscal Year that ends after 30 June 2028, no penalties or sanctions shall apply in connection with the filing of a Top-up Tax Return or the Pillar Two Information Return where the Federal Tax Authority considers that an MNE Group has taken reasonable measures to ensure the correct application of the provisions of this Decision.

14.4 The Minister may determine how other provisions of Federal Decree-Law No. 47 of 2022 referred to above may apply to this Decision.