1. Expenditure incurred wholly and exclusively for the purposes of the Taxable Person’s Business that is not capital in nature shall be deductible in the Tax Period in which it is incurred, subject to the provisions of this Decree-Law.
2. For the purposes of calculating the Taxable Income for a Tax Period, no deduction is allowed for the following:
a) Expenditure not incurred for the purposes of the Taxable Person’s Business.
b) Expenditure incurred in deriving Exempt Income.
c) Losses not connected with or arising out of the Taxable Person’s Business.
d) Such other expenditure as may be specified in a decision issued by the Cabinet at the suggestion of the Minister.
3. If expenditure is incurred for more than one purpose, a deduction shall be allowed for:
a) Any identifiable part or proportion of the expenditure incurred wholly and exclusively for the purposes of deriving Taxable Income.
b) An appropriate proportion of any unidentifiable part or proportion of the expenditure incurred for the purposes of deriving Taxable Income that has been determined on a fair and reasonable basis, having regard to the relevant facts and circumstances of the Taxable Person’s Business.
1. No deduction shall be allowed for Interest expenditure incurred on a loan obtained, directly or indirectly, from a Related Party in respect of any of the following transactions:
a) A dividend or profit distribution to a Related Party.
b) A redemption, repurchase, reduction or return of share capital to a Related Party.
c) A capital contribution to a Related Party.
d) The acquisition of an ownership interest in a Person who is or becomes a Related Party following the acquisition.
2. Clause 1 of this Article shall not apply where the Taxable Person can demonstrate that the main purpose of obtaining the loan and carrying out the transaction referred to under Clause 1 of this Article is not to gain a Corporate Tax advantage.
3. For the purposes of Clause 2 of this Article, no Corporate Tax advantage shall be deemed to arise where the Related Party is subject to Corporate Tax or a tax of a similar character under the applicable legislation of a foreign jurisdiction on the Interest at a rate not less than the rate specified in paragraph (b) of Clause 1 of Article 3 of this Decree-Law.
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Article 32:Entertainment expenses
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1. Subject to Article 28 of this Decree-Law, a Taxable Person shall be allowed to deduct 50% (fifty percent) of any entertainment, amusement, or recreation expenditure incurred during a Tax Period.
2. Clause 1 of this Article applies to any expenditure incurred for the purposes of receiving and entertaining the Taxable Person’s customers, shareholders, suppliers or other business partners, including, but not limited to, expenditure in connection with any of the following:
a) Meals.
b) Accommodation.
c) Transportation.
d) Admission fees.
e) Facilities and equipment used in connection with such entertainment, amusement or recreation.
f) Such other expenditure as specified by the Minister.
1. Donations, grants or gifts made to an entity that is not a Qualifying Public Benefit Entity.
2. Fines and penalties, other than amounts awarded as compensation for damages or breach of contract.
3. Bribes or other illicit payments.
4. Dividends, profit distributions or benefits of a similar nature paid to an owner of the Taxable Person.
5. Amounts withdrawn from the Business by a natural person who is a Taxable Person under paragraph (c) of Clause 3 of Article 11 of this Decree-Law or a partner in an Unincorporated Partnership.
6. Corporate Tax imposed on a Taxable Person under this Decree-Law.
7. Input Value Added Tax incurred by a Taxable Person that is recoverable under Federal Decree-Law No. (8) of 2017 referred to in the preamble and what replaces it.
8. Tax on income imposed on the Taxable Person outside the State.
9. Such other expenditure as specified in a decision issued by the Cabinet at the suggestion of the Minister.
@endif
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Article 34:Transactions with related parties and connected persons
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Transactions with related parties and connected persons
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Add/Less: Unrealised accounting gains and losses adjustments
Unrealised losses
Article 20 : Unrealised gain and losses
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Less : Exempt Income
Article 22:Dividend and profit distribution from UAE company
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