Newsletter | Corporate Tax – No.6


A Person conducting Extractive Business can claim exemption, provided it meets all the following conditions: The Person
• must hold an interest in a right, concession or license issued by a Local Government for undertaking Extractive Business.
• is subject to tax under the applicable law of an Emirate
• notifies the Ministry of Finance of the above in the form and manner agreed with the Local Government.

Taxing the Extractive Businesses under the UAE Corporate Tax Law

If such a Person engages in Extractive as well as other Business that is taxable under the UAE Corporate Tax Law,
then following treatmentshall apply

  • Income from Extractive Business shall be taxed according to the applicable law of the Emirate in question

  • The Person shall not be considered to derive income from other Business, where two conditions are met • The other Business is ancillary to the Person’s Extractive Business; and • The Revenue of such other Business does not exceed 5% of the total Revenue

  • The other Business shall be treated as an independent Business, and financial statements shall be kept for this Business separately from the Extractive Business

  • The Person shall calculate the Taxable Income for its other Business independently for each Tax Period in accordance with the provisions of the UAE Corporate Tax Law

  • Any common expenditure between Extractive and other Business shall be apportioned in ratio of the respective Revenues for the Tax Period, unless law of the Emirate allows a different proportion

  • Transactions between the Extractive Business and the other Business of the same Person shall be considered Related Party transactions unless the other Business is exempt from Corporate Tax under Article 8

The Article addresses the possibility that an Emirate may impose a different type of tax on the income of the Person conducting Extractive Business, e.g., royalty or revenue tax, etc.

Dr Abhishek Jajoo

Founder & Chairman

Serial Entrepreneur with expertise on REGTECH & Risk Management

Muhammad Altaf Hussain

Partner, Tax & Advisory

Ex Big 4 with 24 years of experience in Taxation, Advisory & Assurance

Harsh Bhojani

Associate Director

Ex Big 4 with 9+ years of post qualification experience in taxation advisory and compliances

Ajai Subramanian


Ex Big 4 with 8+ years of post qualification experience in tax advisory, compliance and litigation

UAE Corporate Tax
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