Mastering Corporate Income Tax

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Mastering Corporate Income Tax

د.إ 4.500,00

Corporate Tax is a complex area of taxation and without a proper appreciation of the rules, it is easy for costly mistakes to occur. This comprehensive course will help businesses involved in the preparation of the Corporate Tax return appreciate the rules and regulations and how they should be applied.  It demonstrates the most effective ways to ensure compliance, correct interpretation of the laws, and to reduce the risks for non-compliances and guides you through the various tax reliefs available.

The course will examine all the key aspects of the Corporate Tax and clearly understand Federal Decree-Law No. 47 of 2022. It will explain in details all the relevant provisions of the Decree-law and demonstrate the scenarios in actual applications.

Who should Attend

This course is intended for newcomers to corporate tax, as well as those requiring a refresher on the basic principles. Its main objective is to give attendees a thorough grounding in the basics of corporate tax in the UAE and specifically, Federal Decree-Law No. 47 of 2022.

  • Accountant
  • General Accountants
  • Management Accountant
  • Tax Accountant
  • Financial Accountant
  • Finance Manager
  • Financial Analyst
  • Internal auditors
Category:

Description

BENEFITS

 

This course is suitable for:

 

  • Those who wanted to understand the Federal Decree-Law No. 47 of 2022 and prepare before its affectivity date
  • Staff seeking to expand their taxation knowledge and skills into additional areas of expertise
  • Finance Department staff who have a basic understanding of the main concepts but wanted to gain a d=in-depth knowledge from the experts and actual practitioner

 

DAY CHAPTERS TOPIC Reference
1 Introduction Preface
What is corporate income tax
How corporate tax works
Rationale behind implementation of UAE CT
Timeline of taxation in UAE
Other regulations to consider and to comply
Key principles of UAE CT regime
Chapter 1 1.  General Provision of the Law
1.1 Mastery of basic definitions Article 1
Chapter 2 2.1 Imposition of Corporate Tax and Applicable Rates Article 2
2.1.1 Imposition of Corporate Tax
2.1.2 Who are liable to UAE CIT Law
2.2 Corporate Tax Rate Article 3
2.2.1 Mainland and free zone for VAT purposes
2.2.2 Mainland and free zone for UAE under CIT Law
2.3 Standard UAE CIT tax rate
2.3.1 Qualifying free zone tax rate
Chapter 3 3. Exempt Person Article 4
3.1 Who are considered as exempt persons
3.2 Exemption to a juridical person from UAE CIT Law
3.3 Inherently exempted from CIT
3.4 Exemption by application to a tax period
3.5 Exemption application
3.6 Cessation of exemption
3.7 Government entities Article 5
3.7.1 Government entities exemptions
3.7.2 Government conducting business activities
3.7.3 Government and related parties transactions
3.7.4 Government entities application as a single person
3.8 Government controlled entities Article 6
3.8.1 Government controlled entities exemptions
3.8.2 Government conducting business activities
3.8.3 Government controlled entities application as a single person
3.9 Extractive business Article 7
3.9.1 What is extractive business under CIT Law?
3.9.2 Meaning of income from extractive business
3.9.3 Natural resources covered for extractive business
3.9.4 Taxability of income from extractive business
3.9.5 Person carrying extractive business and other taxable business
3.9.6 Person carrying extractive business and other business
3.9.7 Calculation of taxable income of Other business
3.9.8 Transactions between extractive business and other business to be considered as related party transactions
3.9.9 Non-applicability of exemption
3.10 Non extractive business Article 8
3.10.1 Meaning of income from non extractive business
3.10.2 Taxability of income from non extractive business
3.10.3 Person carrying non-extractive business and other taxable business
3.10.4 Carrying non-extractive business and other business
3.10.5 Calculation of taxable income of ‘Other Business’ under UAE Corporate tax of non-extractive business
3.10.6 Transactions between non-extractive business and other business on related party transactions
3.10.7 Non-applicability of exemption under article 8
3.11 Qualifying Public Benefit Entity Article 9
3.11.1 Conditions to meet the exemption
3.11.2 Affectivity of exemptions
3.11.3 Monitoring by the Authority
3.12 Qualifying Investment Fund Article 10
3.12.1 Conditions to meet the exemption
3.12.2 Monitoring by the Authority
Chapter 4 4. Taxable person and Corporate tax base
4.1 Coverage of Taxable Person Article 4
4.2 What is a tax base and how it works
4.3 Taxable person Article 11
4.4 Who are resident person?
4.4.1 Coverage of incorporated in the UAE
4.4.2 Incorporated outside the UAE but effectively managed and controlled in UAE
4.4.2 .1 Discussion of effective management
4.4.2 .2 Discussions on control
4.5 Who are non-resident person?
4.6 What is a Tax Base Article 12
4.6.1 Which income is taxable for resident or non-resident?
4.7 Meaning and coverage of UAE sourced income Article 13
4.8 UAE sourced income – Payment attributable to UAE PE of a foreign company
4.9 UAE sourced income – Activities or contracts performed in the UAE
4.10 UAE sourced income – Income from the sale of goods in the state
4.11 UAE sourced income – Provision of services that are rendered or utilized or benefitted from in the state
4.12 UAE sourced income – Income from contract wholly or partly performed or benefitted from in the state
4.13 UAE sourced income – Movable or immovable property in the state
4.14 UAE sourced income – Income from disposal of shares or capital of a resident person
4.15  Rights to use intangible or intellectual property in UAE
4.16 Interest paid to a non-resident
4.17 Insurance or reinsurance premiums
4.18 Permanent establishment Article 14
4.19 What constitutes​ as permanent establishment (PE)?
4.19.1 Fixed Place PE and Agency PE
4.20 Fixed or permanent place of business​
4.21 Specific activities exempted from constituting a PE
4.22 Non applicability of exclusion
4.23 Authority on behalf of a non-resident person
Independent agent
4.24 Conditions imposed by Minister of finance
4.25 Investment manager exemption Article 15
4.26 When would an investment manager not be considered as a PE
4.27 Conditions for claiming non permanent establishment status for investment manager
4.28 Meaning of transaction for the purpose of Investment manager PE exemption
4.29 Unincorporated partnership Article 16 –
4.29.1 Definition of Unincorporated partnership
4.29.2 Treatment of unincorporated partnership as a taxable person
4.29.3 Treatment of partner in unincorporated partnership
4.29.4 Allocation of the assets, liabilities, income and expenditure of unincorporated partnership
4.29.5 Computing taxable income of a partner in an unincorporated partnership
4.29.6 Treatment of interest paid by inincorporated partnership to a partner on their capital account
4.29.7 Treatment of foreign tax incurred by the unincorporated partnership
4.29.8 Conditions for treating foreign partnership as unincorporated partnership
4.29.9 Application to authority to treat unincorporated partnership as taxable person
4.29.10 Effect of approval of application
4.29.11 Effective period for treatment of UIP as a taxable person after approval of application
4.30 Family Foundation Article 17
4.30.1 Application for exemption
Chapter 5 5.  Free Zone Person Article 18
5.1 UAE Corporate Tax on Free zone entities
5.2 Definition of free zone person under UAE Corporate Tax?
5.3 Taxability of UAE Free zone Entities ​
5.4 Taxation of a qualifying free zone
5.5 Free zone CIT impact as per CT Public Consultation Document
5.5.1 Income from other another company within the same free zone
5.5.2 Income from other another company from another free zone
5.5.3 Income from a regulated financial service directed at foreign markets
5.5.4 Income from outside UAE
5.5.5 Branch of Free Zone entity in mainland UAE
5.5.6Passive income from mainland source wherein the Free zone person do not have a Branch in the mainland
5.5.7 Transactions of the Free zone entity with their group companies located in mainland UAE
5.5.8 Income from the sale of goods to UAE by a Free Zone person located in Designated zone
5.5.9 Any other mainland sourced income made by the Free Zone Person
5.6 Election to pay UAE Corporate Tax by a qualifying free zone person Article 19​
5.7 Effectiveness date of the election to be subjected to regular corporate tax rate
5.8 Pros and cons of free zone persons
Chapter 6 6. Calculating Taxable Income
6.1 General rules for determining taxable income Article 20
6.2 Determination of taxable income
6.3 Adjustment to taxable income
6.4 Accounting on accrual basis – Gains and losses that can be considered on realisation basis
6.5 Assets held on capital account
6.6 Liabilities held on capital account
6.7 Assets and liabilities held on revenue account
6.8 Provision for minister to provide directions
6.9 Application to authority for change in accounting basis – From cash basis to accrual basis
6.10 Conflict  between provision of decree law and accounting standards
6.11 Small business relief Article 21
6.12 Small business relief – Definition
6.13 Small business relief possible conditions
6.14 Provisions not applicable on person eligible for small business relief
6.15 Compliance regulations on small business relief
Chapter 7 7. Exempt Income
7.1 General rules for determining taxable income Article 20
7.2 Exempt income covered Article 22
7.3 Participation exemption Article 23
7.4 Conditions for participation income exemption
7.5 Establishing participation definition
7.6 Establishing participation interest under tax laws
7.7 Participation interest in qualifying free zone person and exempt person
7.8 Types of income exempted after fulfilling participation income exemption conditions
7.9 Other conditions and regulations on participation exemption
7.10 Foreign permanent establishment exemption Article 24
7.11 Income exemption on foreign permanent establishment
7.12 Other provisions on income exemption rule for foreign PE
7.13 Non-resident income from operating aircrafts or ships in international traffic Article 25
7.14 Non-resident specified business
Chapter 8 8. Reliefs
8.1 Transfers Within a Qualifying Group Article 26
8.2 Transfer of assets and liabilities between two taxable members of a qualifying group​
8.3 Conditions to claim exemption on transfer of assets or liabilities within a qualifying group​
8.4 Impact of meeting conditions
8. 5 Withdrawal of exemption under Article 26.2 on transfer of assets or liabilities ​
8.6 Business restructuring relief Article 27
8.7 When is business restructuring relief available
8.8 Conditions for claiming business restructuring relief
8.9 Non-applicability of Article 27.1
Chapter 9 9. Deductions
9.1 Expenditure deductible Article 28
9.2 Expenditure not allowed as deduction
9.3 Expenditure incurred for more than one purpose
9.4 Interest deductible  Article 29
9.5 General interest deduction limitation Article 30
9.6 Examples of general interest deduction limitation
9.7 Non applicability of interest deduction limitation
9.8 Specific Interest Deduction Limitation Rule Article 31
9.9 Taxable person and consolidation of accounts
9.10 Deductibility of entertainment expenditure   Article 32
9.11 Example of entertainment expenditure
9.12 Non-deductible expenditure Article 33
Chapter 10 10.1 Transactions with Related Parties and Connected Persons
10.2 Arm’s Length Principle Article 34
10.3 Applicability of ALP on related party transaction
10.4 Different methods to determine ALP
10.5 Application of non-prescribed methods to determine ALP
10.6 Factors to be considered for application of TP methods to determine ALP
10.7 Other provisions on ALP    :
10.8 Adjustments by federal tax authority
10.9 Corresponding adjustments by federal tax authority to related party
10.10 Adjustments made by foreign competent authority
10.11 Related Parties and Control Article 35
10.12 Taxation of Connected person
10.13 Payments to connected person Article 36
10.14 Who are connected person under UAE Corporate Tax ?
10.15 Owner of a connected person under UAE Corporate Tax
10.16 Connected person of a partner in unincorporated partnership
10.17 How would market value be determined
10.18 Payments to connected person – Exemption Article 36
10.19 Related parties and control Article 35
10.20 Transactions covered under  UAE Tranfer Price Law
10.21 Transactions covered under  UAE Tranfer Price Law – Person and its permanent establishment
10.22 Two ore more person partner in unincorporated partnership
10.23 Trustee etc of a trust or foundation
10.24 What is the meaning of control under article 35 to determine related party relationship?
10.25 Control to determine related party relationship – Control Exercise 50% or more of voting rights
10.26 Control to determine related party relationship – Determine composition of 50% or more of board of directors
10.27 Control to determine related party relationship – Determine – Control – Receives 50% or more of the profits
10.30 Arm’s length principle Article 34 –
10.31 Applicability of arm’s length principles on related party transaction
10.32 Different methods to determine arm’s length principles
10.33 Application of non-prescribed methods to determine ALP
10.34 Factors to be considered for application of TP methods to determine arm’s length principles
10.35 Other provisions on arm’s length principles
10.36 Corresponding adjustments to related party
10.37 Adjustments made by foreign competent authority
Chapter 11 11. Tax Loss Provisions
11.1 Treatment of tax losses
11.2 Maximum tax losses that can be carried forward and period of carry forward of tax losses   ​
11.3 Brought forward tax losses which are not allowed to be set off
11.4 Set off and carry forward of tax losses under UAE Corporate Tax – Practical Examples
11.5 Ownership conditions for set off and carry forward of tax losses
Chapter 12 11. Tax Loss Provisions
11.1 Tax group Article 40 –
11.2 Parent company to form a tax group with subsidiary company
11.3 Conditions necessary for parent company to form a tax group with subsidiary company
11.4 Formation of tax group in case of government entity
11.5 Implications & duties of the company in a tax group
11.6 Obligation of the parent company and subsidiary company
11.7 Circumstances under which subsidiary can the tax group
11.8 Circumstances under which tax group will cease to exist
11.9 Circumstances under which parent company can make an application to be replaced by another parent company w/o discontinuing tax group –
11.10 Date of formation and cessation of a tax group Article 41
11.11 Computing taxable income of a tax group Article 42
11.12 Computing taxable income of a UAE tax group Article 42
11.13 Unutilised tax losses
13.14 Cessation of a tax group
Chapter 13 13. Calculation of Corporate Tax Payable
13.1 Calculation of corporate tax payable Chapter 13
13.2 Currency for calculating UAE Corporate tax Article 43
13.3 Calculation and settlement of Corporate tax Article 44
13.4 Withholding tax under UAE Corporate tax Article 45
13.5 Withholding tax on Non PE income of Foreign company  Article 45
13.6 Withholding tax credit Article 46
13.70 Foreign tax credit Article 47
Chapter 14 14 Payment and Refund of Corporate Tax
14.1 Tax payment – Article 48
14.2 Tax refund – Article 49
Chapter 15 15. Anti-Abuse Rules
15.1 Anti abuse rules Article 50 –
15.2 General anti-abuse rule
15.3 What is corporate tax advantage?
15.4 Determination by federal tax authority if there is corporate tax advantage
15.5 The Authority to issue assessment
15.6 Authority to issue assessment if determination is made
15.7 Determining transactions or arrangements on which anti-abuse law applies
Chapter 16 16. Tax Registration and Deregistration
16.1 Tax Registration
16.1.1 requirements
16.1.2 Ste-by-step procedures
16.2 Tax Registration    – Article 51
Deregistration from UAE Corporate Tax Article 52
Chapter 17 17 Tax return Article 53
17.1 Important points applicable in a tax return
17.2 Financial Statement Article 54
17.3 Transfer pricing documentation Article 55
17.4 Record Keeping Article 56
17.5 Tax Period Article 57
17.6 Change of Tax Period Article 58
17.7 Clarifications from FTA Article 59
Chapter 18 18 Violations and Penalties
18.1 Corporate tax assessment and penalties Article 60
Chapter 19 19 Transitional Rules
19.1 Transitional rules Article 61
19.1.2 Opening balance sheet and financial year of the taxable person
19.1.3 Opening balance sheet and arm’s length principle
Chapter 20 20 Closing provisions
20.1 Delegation of power Article 62
20.2 Administrative policies and procedures on requirements imposed on person Article 63
20.3 Cooperating with the authority Article 64
20.4 Revenue sharing Article 65
20.5 International agreements Article 66
20.6 Implementing decisions Article 67
20.7 Cancellation of Conflicting Provisions Article 68
20.8 Application of this Decree-Law to Tax Periods Article 69
20.9 Commencement date of the law
20.20 Publication and Application of this Decree-Law Article 70
20.21 Effectively date of the Law
Chapter 22 22 Overview of articles of OECD BEPS
22.1 Introduction to BEPS and its Action Plans
22.2 An Overview of Transfer Pricing
22.3 Development of UAE CT Transfer Pricing Regulations
22.4 Comparability Analysis
22.5 Selection or rejection of comparable
22.6 Timing issues in comparability
22.7 Arm’s length range
22.8 Selection of most appropriate method
22.9 Transfer Pricing Study Report
22.10 BEPS requirements Action Plan 13 – Concept of 3 tiered system
22.10.1 master File
22.10.2 Local file maintenance

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