Investment Funds and Investment Managers

Contents

1. Glossary

2. Introduction

1. 2.1. Overview

   2.2. Purpose of this guide

   2.3. Who should read this guide?

   2.4. How to use this guide

   2.5. Legislative references

   2.6. Status of this guide

3. What are investment funds and investment managers?

1. 3.1. Investment funds landscape in the UAE

   3.2. Rationale for exempting Qualifying Investment Funds

4. Investment Funds and the Corporate Tax Law

1. 4.1. Corporate Tax treatment of investment funds

   1. 4.1.1. Treatment of investment fund entities that are Resident Persons

      4.1.2. Treatment of investment fund entities that are Unincorporated Partnerships

      4.1.3. Treatment of non-resident investment funds

   4.2. Treatment for investment managers

   4.3. Overview of Qualifying Investment Fund status

   1. 4.3.1. Impact of Qualifying Investment Fund status

   4.4. Treatment of investors in a Qualifying Investment Fund

   1. 4.4.1. Inclusion of the fund’s net income in the income of investors

      4.4.2. Allocation of income between Exempt Income, Interest income, income from Immovable Property in the UAE and other income

      4.4.3. Time apportionment of income

      4.4.4. Treatment of distributions

      4.4.5. Application of other Corporate Tax provisions

      4.4.6. Treatment of Exempt Persons held by Qualifying Investment Funds

      4.4.7. Impact of ceasing to be part of a Qualifying Group

      4.4.8. Impact of leaving a Tax Group or causing a Tax Group to cease to exist

      4.4.9. Impact on relief for Tax Losses

5. Conditions for being a Qualifying Investment Fund