Who has to pay Corporate Tax in the UAE?

3. Corporate Tax Registration Corporate Tax is a self-assessment regime. This means that a Person is responsible for assessing whether they are in scope of Corporate Tax, and whether they will need to fulfil any Corporate Tax obligations. Generally, Persons who determine they are within the scope of Corporate Tax is required to register for Corporate Tax. This will allow them to fulfil their Corporate Tax obligations, such as submitting a Corporate Tax Return and paying any Corporate Tax due. Broadly, Corporate Tax applies to the following “Taxable Persons”: • UAE companies and other juridical persons that are incorporated or effectively managed and controlled in the UAE; • Natural persons (individuals) who conduct a taxable Business or Business Activity in the UAE as specified in Cabinet Decision No. 49 of 2023; • Non-resident juridical persons (foreign legal entities) that have a Permanent Establishment in the UAE; • Non-resident juridical persons (foreign legal entities) that have a nexus in the UAE arising from earning income from any Immovable Property in the UAE as specified in Cabinet Decision No. 56 of 2023; • Juridical persons established in a UAE Free Zone (if meeting the conditions to be considered a Qualifying Free Zone Person, they may benefit from a Corporate Tax rate of 0% on their Qualifying Income); • Non-resident persons that do not have a Permanent Establishment in the UAE and earn State Sourced Income; and • Non-resident persons that have a Permanent Establishment in the UAE and earn State Sourced Income that is not related to their Permanent Establishment. Certain categories of Persons will not be required to register for Corporate Tax if they are specifically excluded in the relevant decision.1 The requirement to register and provide the relevant supporting documentation depends on whether the Person is a natural person (i.e. an individual) or a juridical person (i.e. a legal entity), and whether they are considered a Taxable Person (i.e. a Resident Person or a Non-Resident Person), or an Exempt Person for Corporate Tax. The table below sets out who will be required to register for Corporate Tax. More details on each of these categories are included in the sections below. 1 Ministerial Decision No. 43 of 2023. Corporate Tax Guide I Registration of Resident Juridical Persons I CTGRJP1 10

3. Tax Registration obligations The UAE Corporate Tax regime is a self-assessment regime. This means that a natural person is responsible for assessing whether they are within the scope of Corporate Tax, and whether they will need to fulfil any Corporate Tax obligations. Generally, natural persons who are within the scope of Corporate Tax are required to register for Corporate Tax purposes. This will allow them to fulfil their Corporate Tax obligations, such as submitting a Corporate Tax Return and paying any Corporate Tax due. A natural person will fall within the scope of Corporate Tax and thus be required to register for Corporate Tax purposes, where: • he/she is a Resident Person; • he/she is a Non-Resident Person with a Permanent Establishment in the UAE; • he/she carries on a Business or Business Activity in respect of which he/she derives a total Turnover in excess of AED 1 million; and • the Turnover is not derived from: o Wage, o Personal Investment, or o Real Estate Investment. Each of the above listed concepts and requirements is explained in Section 3.2.5. 3.1. Who is a Taxable Person? A Taxable Person could either be a natural person or a juridical person. Most Taxable Persons will be required to register for Corporate Tax purposes, with the exception of Non-Resident Persons that derive only State Sourced Income without having a Permanent Establishment in the UAE. The circumstances under which a natural person will be treated as a Taxable Person who is required to register for Corporate Tax are set out below. 3.2. Who is a natural person? The term natural person takes its ordinary meaning, and refers to a living human person of any age, whether resident in the UAE or elsewhere. A natural person would only be subject to Corporate Tax insofar as he/she conducts a Business or Business Activity in the UAE. This includes sole establishments and individual partners in Unincorporated Partnerships that conduct a Business or Business Activity in the UAE. Corporate Tax Guide | Registration of Natural Persons | CTGRNP1 10