In Episode 4 of the Rethink Corporate Tax podcast series, Neil Guthrie (Head of Finance & Tax at Rethink) and Keerthi Voodimudi (Director of Tax) focus on the corporate tax implications for holding companies and special purpose vehicles (SPVs)—particularly those based in Free Zones like DIFC and ADGM.
As many of these structures are established for asset protection, capital raising, or risk isolation, it’s essential to understand how the UAE CT regime applies to them.
Key discussion points include:
Key discussion points include:
- Why holding companies and SPVs must register for corporate tax, maintain accounting records, and comply with transfer pricing and economic substance requirements
- The tax treatment of common income types, including dividends, capital gains, interest, and rental income
- Conditions under which participation exemptions may apply to exempt certain income from tax
- The implications of income repatriation, including the current 0% withholding tax
- Risks posed by transfer pricing and the General Anti-Abuse Rules (GAAR), which are already in force
- How foreign entities may be deemed UAE tax residents if they are managed and controlled from the UAE
With key cabinet decisions still pending—particularly around the definition of qualifying income—businesses should begin scenario planning and ensure their current structures are compliant.
Listen to Episode 5 to understand how CT will affect your SPVs and holding companies, and what proactive steps should be taken now.
