In Episode 3 of Rethink’s Corporate Tax podcast series, Neil Guthrie (Head of Finance & Tax at Rethink) is joined by Keerthi Voodimudi (Director of Tax) explore several more complex—but highly relevant—provisions within the UAE’s corporate tax framework. This instalment is particularly useful for medium and large businesses, those operating in group structures, and foreign entities with UAE exposure.
Key discussion points include:
- The difference between resident and non-resident taxable persons, and how businesses may be brought into scope based on incorporation or management location
- What types of income are exempt, including certain dividends, capital gains, and foreign branch profits (subject to conditions)
- How tax losses can be carried forward or transferred within group structures, including caps and qualifying thresholds
- The introduction of transfer pricing regulations, and how pricing between group companies—particularly across mainland and free zone entities—will need to reflect arm’s length principles
The episode provides examples of how legal entity structures, profit allocation, and even sourcing decisions may need to shift under the new regime.
Transfer pricing and residency rules are not theoretical—they will directly influence future tax liability for UAE and international groups alike.
Businesses are encouraged to model scenarios now, and ensure they’re not only compliant but optimised for the structure of the law.
Listen to Episode 3 for a concise breakdown of these more technical corporate tax elements—and what they could mean for your current structure.
