UAE Tax LawLaw No. (1) of 2024 Concerning Tax on Foreign Banks Operating in the Emirate of Dubai

Article (2) The following words and expressions, wherever mentioned in this Law, will have the meaning indicated opposite each of them unless the context implies otherwise: UAE: The United Arab Emirates. Emirate: The Emirate of Dubai. Ruler: His Highness the Ruler of Dubai. CBUAE: The Central Bank of the United Arab Emirates. SFC: The Supreme Fiscal Committee in the Emirate of Dubai. DOF: The Department of Finance. FAA: The Financial Audit Authority. Director General: The director general of the DOF. Corporate Tax Law: Federal Law by Decree No. (47) of 2022 Concerning Corporate and Business Tax and its amendments. Tax: The tax imposed on a Taxable Person under this Law. Foreign Bank: A branch of a foreign bank licensed by the CBUAE to operate in the UAE in accordance with the legislation applicable to the CBUAE. Taxable Person: A Foreign Bank and its branches that are licensed by the CBUAE to operate in the Emirate. Tax Period: A period of time in respect of which a Taxable Person must submit a Tax Return and calculate the relevant due Tax.

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Law No. (1) of 2024 Concerning Tax on Foreign Banks Operating in the Emirate of Dubai Page 3 of 14 Taxable Income: The revenue realised by a Taxable Person within the Emirate during a Tax Period, which is calculated in accordance with the provisions of this Law. Tax Return: The information and data that must be provided to the DOF by a Taxable Person on the forms prescribed by the DOF and in accordance with the relevant resolutions issued by it. Tax Audit: A process undertaken by an Auditor to examine the accounting records, books, and documents; or any information or data related to the Tax due from a Taxable Person. Tax Assessment: A decision issued by the DOF determining the amount of Tax due from a Taxable Person based on the findings of a Tax Audit. Voluntary Disclosure: A statement submitted by a Taxable Person to the DOF, under this Law and the resolutions issued in pursuance hereof, notifying it of any error, deficiency, or omission in a Tax Return or Tax Assessment. Auditor: Any Person authorised by the FAA to audit a Taxable Person. Tax Evasion: A Taxable Person’s use of illegal means resulting in the under- assessment or non-payment of the amount of due Tax, or a Tax refund to which he is not entitled. Scope of Application

Article (5) When calculating a Taxable Income, the following will be observed: 1. The rules and regulations approved by the Director General regarding: a. the method of calculating Joint Revenues and Joint Expenditures; b. the head office expenditures and the Regional Management Expenditures; c. the unrealised losses and gains from the Taxable Income; d. any profits that are not included in the income statement; and e. any other matters required to be considered when calculating the Taxable Income. 2. the provisions of the Corporate Tax Law and the resolutions issued in pursuance thereof, in any cases other than those covered by the rules and regulations approved by the Director General for calculation of the Taxable Income. Submission of Tax Returns and Payment of Taxes

Article (6) a. A Taxable Person must, within the time frame prescribed by the Director General, provide the DOF with: 1. the Tax Return for the outgoing Tax Period, on the relevant form prescribed by the DOF; 2. the Taxable Person’s financial statements and financial notes; 3. the amount of Tax due in respect of the outgoing Tax Period, together with the documents supporting the method of calculation of that amount; and 4. the tax rate applicable to the Taxable Person, and the amount of Tax paid by him, under the Corporate Tax Law.

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Law No. (1) of 2024 Concerning Tax on Foreign Banks Operating in the Emirate of Dubai Page 5 of 14 b. The financial statements and financial notes of a Foreign Bank must be certified by an accredited external auditor. c. A Tax Return submitted to the DOF will not be accepted unless it includes the basic information determined in the form prescribed by the DOF. d. A Taxable Person is responsible for the accuracy of the information and data set forth in the Tax Return, financial statements, and financial notes; and all other data and information provided by him to the DOF or the FAA. Voluntary Disclosure

Article (7) a. Where a Taxable Person becomes aware that a Tax Return submitted by him to the DOF, or a Tax Assessment sent to him by the DOF, is incorrect, resulting in under- assessment of the Tax due under this Law, the Taxable Person must correct the Tax Return, or the information based on which the Tax Assessment is made, by submitting a Voluntary Disclosure; and must pay the outstanding difference in Tax within thirty (30) days from the date on which he becomes aware of the same. b. Where a Taxable Person becomes aware that a Tax Return submitted by him to the DOF, or a Tax Assessment sent to him by the DOF, is incorrect, resulting in over- assessment of the Tax due under this Law, the Taxable Person may submit a Voluntary Disclosure within thirty (30) days from the date on which he becomes aware of the same. In that case, the Taxable Person must notify the DOF of an appropriate refund method, either through making the refund to his bank account or considering the difference in Tax as an advance payment towards the Tax due in respect of the next Tax Period. c. The Voluntary Disclosure referred to in paragraphs (a) and (b) of this Article will be submitted on the relevant forms and in accordance with the procedures prescribed by the DOF. Audit of Tax Returns and Voluntary Disclosures

Article (9) a. An Auditor will conduct the Tax Audit of a Taxable Person to verify his compliance with the provisions of this Law. The audit may be conducted at the offices of the FAA; at the place of business of the Taxable Person; or at any other place where the Taxable Person keeps his records, in which case the Taxable Person must be notified at least five (5) days before the date of conducting the Tax Audit. b. For the purpose of performing the Tax Audit duties, an Auditor will have the authority to access all documents, information, records, and data at the Taxable Person’s place of business or at the place where the Taxable Person keeps his records, provided that these documents, information, records, and data are relevant for Tax purposes. c. Notwithstanding the provisions of paragraph (a) of this Article, an Auditor will have the right to access any place of business of the Taxable Person or any place where he keeps his records, without notifying him in advance of the Tax Audit, in any of the following cases: 1. where the FAA has substantial grounds to believe that the Taxable Person is involved or implicated in Tax Evasion; 2. where the FAA has substantial grounds to believe that the Taxable Person is concealing any Tax-related data or information; or 3. where the Taxable Person is notified in advance of the Tax Audit but attempts to prevent the Auditor from accessing the place where the Tax Audit is to be conducted. d. A Tax Audit will be conducted during the official working hours of the FAA. However, where necessary, the Tax Audit may be conducted outside of these working hours pursuant to a decision of the FAA Director General. e. A person who is subject to Tax Audit, or any other person whose work is related to the Tax Audit, must provide all possible facilitations and assistance to the Auditor to enable him to perform his duties. f. The DOF and the FAA will have the right to re-audit any matter that has been previously audited if new information emerges which may impact the Tax Audit findings.

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Law No. (1) of 2024 Concerning Tax on Foreign Banks Operating in the Emirate of Dubai Page 7 of 14 Obtaining Records and Documents

Article (14) a. A Taxable Person may file a challenge with the DOF in respect of the amount of Tax or fine imposed on him under this Law. This challenge will be admissible subject to the following: 1. The challenge must be in writing, reasoned, and supported by the relevant documents and facts. 2. The challenge must be filed within twenty (20) days from the date on which the Taxable Person is notified of the Tax Assessment and the amount of the due Tax, or the imposed fine. 3. The Taxable Person must pay at least fifty percent (50%) of the amount of the due Tax or imposed fine. b. The DOF will consider any challenge that meets the requirements referred to in paragraph (a) of this Article through a committee formed for this purpose by the Director General from among the employees of the DOF or other entities. This committee must submit its recommendations in respect of the challenge to the SFC within thirty (30) days from the date of duly filing the challenge. The SFC must determine the challenge by issuing a reasoned decision within ten (10) days from the date of submitting the recommendations to it. c. The DOF will notify the Taxable Person of the SFC decision within five (5) days from the date of its issuance. d. The SFC decision will be deemed final, and may be appealed only before the competent court. Tax Evasion Penalty

Article (15) a. Without prejudice to any stricter penalty stipulated in any other legislation, a Person who commits Tax Evasion by performing any of the acts stipulated in paragraph (b) of this Article will be punished by a fine equal to double the amount of the evaded Tax. b. A Taxable Person will be deemed to have committed Tax Evasion if he: 1. submits an incorrect Tax Return, and fails to provide a Voluntary Disclosure in respect thereof within the time limit prescribed by this Law;

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Law No. (1) of 2024 Concerning Tax on Foreign Banks Operating in the Emirate of Dubai Page 9 of 14 2. fails to pay the due Tax or the difference in Tax established by the Tax Audit; 3. understates his actual Taxable Income; 4. manipulates accounting data or provides incorrect, incomplete, or false information, records, or statements; 5. misuses, or causes damage to, any documents prepared by the DOF or the FAA; 6. destroys or conceals any documents, data, or information he is required to maintain and provide to the DOF or the FAA; 7. prevents or precludes the Auditor from performing his duties in a manner that leads to Tax Evasion; or 8. commits any other act or omission aimed at evading, in part or in whole, the payment of Tax. c. Without prejudice to the Taxable Person’s liability for Tax Evasion, where it is established that a third party has directly particpated in or caused Tax Evasion, the same fine imposed on the Taxable Person will be independently imposed on that third party. Delay in Payment of Taxes or Fines

Article (17) a. The Chairman of the Executive Council will issue a resolution determining the acts that constitute administrative violations of this Law and the resolutions issued in pursuance hereof; and the fine prescribed for each violation. The fine for each violation must not exceed five hundred thousand dirhams (AED 500,000.00)

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Law No. (1) of 2024 Concerning Tax on Foreign Banks Operating in the Emirate of Dubai Page 10 of 14 b. Upon repetition of the same administrative violation within two (2) years from the date of the previous violation, the amount of the fine referred to in paragraph (a) of this Article will be doubled. A fine must not exceed one million dirhams (AED 1,000,000.00). Tax Payment Obligation

Article (22) a. Subject to liability, the employees of the DOF and the FAA must maintain the confidentiality of, and not disclose, the information and data which they obtain or to which they have access in the course of implementing the provisions of this Law and the resolutions issued in pursuance hereof; and will remain bound by this confidentiality obligation even after the end of their service. b. Without prejudice to any liability incurred, where applicable, a Person who obtains any data or information related to implementing the provisions of this Law and the resolutions issued in pursuance hereof must not disclose or use the same for any purposes other than those for which it is obtained unless such disclosure or use is requested by the Competent Judicial Authority. c. The Director General will, in coordination with the FAA Director General, issue the bylaws and instructions required for regulating the exchange of the data and information related to implementing the provisions of this Law and the resolutions issued in pursuance hereof. Rules for Collection of Public Funds