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In effectCabinet Resolution

UAE Tax LawCabinet Resolution No. (35) of 2025 Regarding the Determination of the Non-Resident Person's Nexus in the State for the Purpose of Federal Decree by Law No. (47) of 2022 Regarding Taxation of Corporations and Businesses

UAE Federal Decree-Law·Cabinet Resolution No. (35) of 2025

قرار مجلس الوزراء بشأن تحديد صلة الشخص غير المقيم في الدولة لأغراض المرسوم بقانون اتحادي في شأن الضريبة على الشركات والأعمال

Authoritative Arabic version per the official UAE Legislation portal

Issued Date
March 27, 2025
Effective from
March 27, 2025
Articles
8
Last synced
Jun 15, 2026

Plain-language summary

  • Sets when a non-resident person has a taxable link (nexus) to the UAE under the Corporate Tax Law.
  • Applies to foreign companies and entities earning UAE-sourced income without a permanent establishment here.
  • Helps determine if a non-resident must register and pay UAE corporate tax.
  • Issued under Federal Decree-Law No. 47 of 2022 on Taxation of Corporations and Businesses.
  • Relevant for cross-border investors, foreign juridical persons, and non-resident businesses with UAE activities.

Establishes criteria determining when non-resident persons have taxable nexus in the UAE under the Corporate Tax Law, affecting foreign entities earning UAE-sou…

Synced from the official UAE Legislation portal · Plain-language summary by the LEXAI editorial team

Article-level text

Key Articles

8 articles

  1. 1

    Article 1

    Article (1) Definitions The definitions stipulated in Federal Decree by Law No. (47) of 2022 referred to herein shall apply to this Resolution. Otherwise, the following terms and expressions shall have the meanings assigned to each of them, unless the context requires otherwise: Immovable Asset : Refers to any of the following: a. Any plot of land on which rights, interests, or services are established. b. Any building, structure, or engineering work permanently attached to land or fixed to the seabed.

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    Cabinet Resolution of 2025 Regarding the Determination of the Non-Resident Person's Nexus in the State for the Purposes of Federal Decree by Law of 2022 Regarding Taxation of Corporations and Businesses 2 c. Any fixtures or equipment installed as a permanent part of the land or permanently attached to the building, structure, engineering work, or the seabed. Corporate Tax Law : Federal Decree by Law No. (47) of 2022 Regarding Taxation of Corporations and Businesses, as amended.

  2. 2

    Article 2

    Article (2) Nexus in the State For the purposes of Paragraph (c) of Clause (4) of Article (11) of the Corporate Tax Law, a legal person established, created, or otherwise recognized under the legislation of another country or foreign territory shall have a nexus in the State in any of the following cases: 1. Deriving income from immovable property in the State, including income derived from a real right in immovable property, from its sale, disposal, assignment of rights therein, direct use thereof, lease including sublease, or any other form of exploitation thereof. 2. That its income has been adjusted pursuant to Clause (2) of Article (3) of Cabinet Resolution No. (34) of 2025 referred to herein. 3. Its income has been adjusted pursuant to Item (5) of Article (3), or Clause (3) of Article (4) of Cabinet Resolution No. (34) of 2025 referred to herein, and the nexus in the State shall arise from the date of dividend distributions by an investment fund that distributes (80%) eighty percent or more of its income from immovable assets within (9) nine months from the end of the fiscal year of said fund; or the date of acquiring shares in an investment fund that does not distribute such percentage within the aforementioned time period.

  3. 3

    Article 3

    Article (3) Artificial Transfer of Rights in Immovable Assets If a non-resident person makes an artificial transfer of their real right in any immovable assets in the State to another person or disposes thereof in any other manner, and such transfer or disposition is not for a genuine commercial purpose or a non-financial purpose reflecting the economic reality, this shall be considered an arrangement to obtain a corporate tax advantage under Clause (1) of Article (50) of the Corporate Tax Law.

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    Cabinet Resolution of 2025 Regarding the Determination of the Non-Resident Person's Nexus in the State for the Purposes of Federal Decree by Law of 2022 Regarding Taxation of Corporations and Businesses 3

  4. 4

    Article 4

    Article (4) Corporate Tax Registration Requirements A non-resident person who has a nexus in the State pursuant to Article (2) of this Resolution shall register for the corporate tax with the Authority in compliance with Article (51) of the Corporate Tax Law.

  5. 5

    Article 5

    Article (5) Executive Resolutions The Minister may issue the necessary Resolutions to implement any of the provisions of this Resolution.

  6. 6

    Article 6

    Article (6) Repeals 1. Cabinet Resolution No. (56) of 2023 Regarding the Determination of the Non-Resident Person’s Nexus in the State for the purposes of Federal Decree by Law No. (47) of 2022 Regarding Taxation of Corporations and Businesses is hereby repealed, provided that it shall remain in force with respect to tax periods that commenced prior to 1 January 2025. 2. Any provision that contradicts or conflicts with the provisions of this Resolution shall be repealed.

  7. 7

    Article 7

    Article (7) Application of the Resolution to Tax Periods This Resolution shall apply to tax periods commencing on or after 1 January 2025.

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    Cabinet Resolution of 2025 Regarding the Determination of the Non-Resident Person's Nexus in the State for the Purposes of Federal Decree by Law of 2022 Regarding Taxation of Corporations and Businesses 4

  8. 8

    Article 8

    Article (8) Publication and Entry into Force of the Resolution This Resolution shall be published in the Official Gazette and shall enter into force from the date of its publication. Mohammed bin Rashid Al Maktoum Prime Minister Issued by us: On: 27 Ramadan 1446 AH Corresponding to: 27 March 2025 AD

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Note: The Arabic text of this legislation is the authoritative version as per the official UAE Legislation portal.

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