Companies already established in multiple jurisdictions will approach the UAE corporate tax with general familiarity.
However, each face their own difficulties and can be broadly categorised into three camps.
Let’s start with large Emirati family businesses.
Related party transactions must be conducted at arm’s length. This ensures that taxes due to the Ministry of Finance are not unreasonably offset against losses elsewhere.
In a country where one million people are Emirati, these companies are statistically more likely to be familial.
The decree law defines a related party as being related within the fourth degree of kinship or affiliation — grandparent to great-grandchild or individual to second cousin twice removed. Yes, it’s vertical and horizontal.
From a business-ownership perspective, there is a threshold that must be reached for related party transaction rules to come into play.
However, the test is not one individual to another; it is the shareholdings of an individual’s stock.
You add each individual element of ownership together to see whether the threshold is reached.
We are in a time where both the reins of power and ownership are being passed on to growing families. This is by choice or the passing of individuals.
Businesses may sometimes have different ownership structures, meaning the related party position can vary from one transacting entity to the other.
Not only is today’s solution complex, as inheritance occurs, it’s also a moving target.
In camp two are companies operating in two to five jurisdictions. Many upper-end SMEs are in this camp.
Very often, this situation arises due to a business’s decision to split, for example, sales, manufacturing and intellectual property.
Keep in mind their size belies their unlikely existence in multiple jurisdictions. These structures are often driven by supply chain limitations, home country connections, legal traditions and the all-important end-game liquidity event. That’s a future sale of the business in everyday parlance.
The decree law stakes a position on tax domiciling groups as a whole. This means separate entities could be deemed as headquartered in the UAE.
As such, the financial performances of the entities are combined and rolled into one UAE-reporting company.
As part of this, there are tests to be passed to avoid double taxation.
Given the UAE’s competitive corporate tax rate of 9 per cent, double taxation agreements (DTAs) should mean no additional tax burden.
However, that assumes the corporate tax is levied in the other countries where these companies are established.
While the general agreement on pillar two, which dictates a global minimum 15 per cent corporate tax, should theoretically have been actioned by the end of this year, there are countries that have not yet begun the process.
Two new ongoing tasks, which are complex, may now need to be managed: formal group financial consolidation and tax planning. The regulatory reporting that will result is taken as given.
Treasury, the management of a company's finances, will also be affected. Settlement of potential additional tax liabilities and the onboarding and maintenance of employees to navigate the new regime must be paid for.
What should be apparent is how the UAE looks more like the US or the UK as each year passes — add in anti-money laundering regulations and economic substance reporting (ESR).
We are on the early stages of a journey, not the end. This is what growing up quickly, at a corporate level, looks like.
This brings us to the final camp, where large multinational companies (MNCs) reside.
In many ways, they should be the least affected. Ultimately, it’s just one more taxable environment to manage.
Yes, there will need to be transfer pricing exercises conducted, although these should already be in place as part of a company's annual ESR, now in its fourth year as a requirement.
DTAs will need to be dusted off to understand what effect the changes might have. Are we likely to see some changes to the DTAs in place as a result of the UAE's corporate tax?
Taking the UAE in isolation, the question for MNCs is: Why 9 per cent and not 15 per cent?
Do they decide to formulate one solution ahead of the tax launch, with additional measures planned should the rate move upwards?
Does the 6 per cent difference matter that much? In an MNC environment, depending on their tax-planning sensitivity, it can mean a great deal.
The larger effect could be on decisions to delay executing business plans, or worse, failure to activate plans or opportunities lost to other markets.
David Daly is partner at Gulf Tax Accounting Group in the UAE
Profile Box
Company/date started: 2015
Founder/CEO: Mohammed Toraif
Based: Manama, Bahrain
Sector: Sales, Technology, Conservation
Size: (employees/revenue) 4/ 5,000 downloads
Stage: 1 ($100,000)
Investors: Two first-round investors including, 500 Startups, Fawaz Al Gosaibi Holding (Saudi Arabia)
COMPANY PROFILE
Name: Kumulus Water
Started: 2021
Founders: Iheb Triki and Mohamed Ali Abid
Based: Tunisia
Sector: Water technology
Number of staff: 22
Investment raised: $4 million
FA CUP FINAL
Manchester City 6
(D Silva 26', Sterling 38', 81', 87', De Bruyne 61', Jesus 68')
Watford 0
Man of the match: Bernardo Silva (Manchester City)
Specs
Engine: Duel electric motors
Power: 659hp
Torque: 1075Nm
On sale: Available for pre-order now
Price: On request
How to apply for a drone permit
- Individuals must register on UAE Drone app or website using their UAE Pass
- Add all their personal details, including name, nationality, passport number, Emiratis ID, email and phone number
- Upload the training certificate from a centre accredited by the GCAA
- Submit their request
What are the regulations?
- Fly it within visual line of sight
- Never over populated areas
- Ensure maximum flying height of 400 feet (122 metres) above ground level is not crossed
- Users must avoid flying over restricted areas listed on the UAE Drone app
- Only fly the drone during the day, and never at night
- Should have a live feed of the drone flight
- Drones must weigh 5 kg or less
Small Victories: The True Story of Faith No More by Adrian Harte
Jawbone Press
SANCTIONED
- Kirill Shamalov, Russia's youngest billionaire and previously married to Putin's daughter Katarina
- Petr Fradkov, head of recently sanctioned Promsvyazbank and son of former head of Russian Foreign Intelligence, the FSB.
- Denis Bortnikov, Deputy President of Russia's largest bank VTB. He is the son of Alexander Bortnikov, head of the FSB which was responsible for the poisoning of political activist Alexey Navalny in August 2020 with banned chemical agent novichok.
- Yury Slyusar, director of United Aircraft Corporation, a major aircraft manufacturer for the Russian military.
- Elena Aleksandrovna Georgieva, chair of the board of Novikombank, a state-owned defence conglomerate.
The Travel Diaries of Albert Einstein The Far East, Palestine, and Spain, 1922 – 1923
Editor Ze’ev Rosenkranz
Princeton
ANALYSTS’ TOP PICKS OF SAUDI BANKS IN 2019
Analyst: Aqib Mehboob of Saudi Fransi Capital
Top pick: National Commercial Bank
Reason: It will be at the forefront of project financing for government-led projects
Analyst: Shabbir Malik of EFG-Hermes
Top pick: Al Rajhi Bank
Reason: Defensive balance sheet, well positioned in retail segment and positively geared for rising rates
Analyst: Chiradeep Ghosh of Sico Bank
Top pick: Arab National Bank
Reason: Attractive valuation and good growth potential in terms of both balance sheet and dividends
TEST SQUADS
Bangladesh: Mushfiqur Rahim (captain), Tamim Iqbal, Soumya Sarkar, Imrul Kayes, Liton Das, Shakib Al Hasan, Mominul Haque, Nasir Hossain, Sabbir Rahman, Mehedi Hasan, Shafiul Islam, Taijul Islam, Mustafizur Rahman and Taskin Ahmed.
Australia: Steve Smith (captain), David Warner, Ashton Agar, Hilton Cartwright, Pat Cummins, Peter Handscomb, Matthew Wade, Josh Hazlewood, Usman Khawaja, Nathan Lyon, Glenn Maxwell, Matt Renshaw, Mitchell Swepson and Jackson Bird.
F1 2020 calendar
March 15 - Australia, Melbourne; March 22 - Bahrain, Sakhir; April 5 - Vietnam, Hanoi; April 19 - China, Shanghai; May 3 - Netherlands, Zandvoort; May 20 - Spain, Barcelona; May 24 - Monaco, Monaco; June 7 - Azerbaijan, Baku; June 14 - Canada, Montreal; June 28 - France, Le Castellet; July 5 - Austria, Spielberg; July 19 - Great Britain, Silverstone; August 2 - Hungary, Budapest; August 30 - Belgium, Spa; September 6 - Italy, Monza; September 20 - Singapore, Singapore; September 27 - Russia, Sochi; October 11 - Japan, Suzuka; October 25 - United States, Austin; November 1 - Mexico City, Mexico City; November 15 - Brazil, Sao Paulo; November 29 - Abu Dhabi, Abu Dhabi.
Monday's results
- UAE beat Bahrain by 51 runs
- Qatar beat Maldives by 44 runs
- Saudi Arabia beat Kuwait by seven wickets
MATCH INFO
Qalandars 112-4 (10 ovs)
Banton 53 no
Northern Warriors 46 all out (9 ovs)
Kumara 3-10, Garton 3-10, Jordan 2-2, Prasanna 2-7
Qalandars win by six wickets
How to wear a kandura
Dos
- Wear the right fabric for the right season and occasion
- Always ask for the dress code if you don’t know
- Wear a white kandura, white ghutra / shemagh (headwear) and black shoes for work
- Wear 100 per cent cotton under the kandura as most fabrics are polyester
Don’ts
- Wear hamdania for work, always wear a ghutra and agal
- Buy a kandura only based on how it feels; ask questions about the fabric and understand what you are buying
more from Janine di Giovanni
UAE currency: the story behind the money in your pockets
Frankenstein in Baghdad
Ahmed Saadawi
Penguin Press
How to get exposure to gold
Although you can buy gold easily on the Dubai markets, the problem with buying physical bars, coins or jewellery is that you then have storage, security and insurance issues.
A far easier option is to invest in a low-cost exchange traded fund (ETF) that invests in the precious metal instead, for example, ETFS Physical Gold (PHAU) and iShares Physical Gold (SGLN) both track physical gold. The VanEck Vectors Gold Miners ETF invests directly in mining companies.
Alternatively, BlackRock Gold & General seeks to achieve long-term capital growth primarily through an actively managed portfolio of gold mining, commodity and precious-metal related shares. Its largest portfolio holdings include gold miners Newcrest Mining, Barrick Gold Corp, Agnico Eagle Mines and the NewMont Goldcorp.
Brave investors could take on the added risk of buying individual gold mining stocks, many of which have performed wonderfully well lately.
London-listed Centamin is up more than 70 per cent in just three months, although in a sign of its volatility, it is down 5 per cent on two years ago. Trans-Siberian Gold, listed on London's alternative investment market (AIM) for small stocks, has seen its share price almost quadruple from 34p to 124p over the same period, but do not assume this kind of runaway growth can continue for long
However, buying individual equities like these is highly risky, as their share prices can crash just as quickly, which isn't what what you want from a supposedly safe haven.
COMPANY%20PROFILE
%3Cp%3E%3Cstrong%3EName%3A%3C%2Fstrong%3E%20Carzaty%2C%20now%20Kavak%3Cbr%3E%3Cstrong%3EBased%3A%3C%2Fstrong%3E%20Dubai%3Cbr%3E%3Cstrong%3ELaunch%20year%3A%20%3C%2Fstrong%3ECarzaty%20launched%20in%202018%2C%20Kavak%20in%20the%20GCC%20launched%20in%202022%3Cbr%3E%3Cstrong%3ENumber%20of%20employees%3A%3C%2Fstrong%3E%20140%3Cbr%3E%3Cstrong%3ESector%3A%3C%2Fstrong%3E%20Automotive%3Cbr%3E%3Cstrong%3EFunding%3A%20%3C%2Fstrong%3ECarzaty%20raised%20%246m%20in%20equity%20and%20%244m%20in%20debt%3B%20Kavak%20plans%20%24130m%20investment%20in%20the%20GCC%3C%2Fp%3E%0A
COMPANY%20PROFILE
%3Cp%3E%0D%3Cbr%3E%3Cstrong%3ECompany%20name%3A%20%3C%2Fstrong%3EClara%0D%3Cbr%3E%3Cstrong%3EStarted%3A%20%3C%2Fstrong%3E2019%0D%3Cbr%3E%3Cstrong%3EFounders%3A%20%3C%2Fstrong%3EPatrick%20Rogers%2C%20Lee%20McMahon%2C%20Arthur%20Guest%2C%20Ahmed%20Arif%0D%3Cbr%3E%3Cstrong%3EBased%3A%20%3C%2Fstrong%3EDubai%0D%3Cbr%3E%3Cstrong%3EIndustry%3A%20%3C%2Fstrong%3ELegalTech%0D%3Cbr%3E%3Cstrong%3EFunding%20size%3A%3C%2Fstrong%3E%20%244%20million%20of%20seed%20financing%0D%3Cbr%3E%3Cstrong%3EInvestors%3A%20%3C%2Fstrong%3EWamda%20Capital%2C%20Shorooq%20Partners%2C%20Techstars%2C%20500%20Global%2C%20OTF%2C%20Venture%20Souq%2C%20Knuru%20Capital%2C%20Plug%20and%20Play%20and%20The%20LegalTech%20Fund%3C%2Fp%3E%0A
Benefits of first-time home buyers' scheme
- Priority access to new homes from participating developers
- Discounts on sales price of off-plan units
- Flexible payment plans from developers
- Mortgages with better interest rates, faster approval times and reduced fees
- DLD registration fee can be paid through banks or credit cards at zero interest rates
Veere di Wedding
Dir: Shashanka Ghosh
Starring: Kareena Kapoo-Khan, Sonam Kapoor, Swara Bhaskar and Shikha Talsania
Verdict: 4 Stars
The%20specs
%3Cp%3E%3Cstrong%3EEngine%3A%3C%2Fstrong%3E%201.8-litre%204-cyl%20turbo%0D%3Cbr%3E%3Cstrong%3EPower%3A%20%3C%2Fstrong%3E190hp%20at%205%2C200rpm%0D%3Cbr%3E%3Cstrong%3ETorque%3A%3C%2Fstrong%3E%20320Nm%20from%201%2C800-5%2C000rpm%0D%3Cbr%3E%3Cstrong%3ETransmission%3A%20%3C%2Fstrong%3ESeven-speed%20dual-clutch%20auto%0D%3Cbr%3E%3Cstrong%3EFuel%20consumption%3A%3C%2Fstrong%3E%206.7L%2F100km%0D%3Cbr%3E%3Cstrong%3EPrice%3A%3C%2Fstrong%3E%20From%20Dh111%2C195%0D%3Cbr%3E%3Cstrong%3EOn%20sale%3A%20%3C%2Fstrong%3ENow%3C%2Fp%3E%0A
MATCH INFO
Everton 0
Manchester City 2 (Laporte 45 2', Jesus 90 7')
Destroyer
Director: Karyn Kusama
Cast: Nicole Kidman, Toby Kebbell, Sebastian Stan
Rating: 3/5
UAE release: January 31
The specs: Macan Turbo
Engine: Dual synchronous electric motors
Power: 639hp
Torque: 1,130Nm
Transmission: Single-speed automatic
Touring range: 591km
Price: From Dh412,500
On sale: Deliveries start in October
TEAMS
EUROPE:
Justin Rose, Francesco Molinari, Tyrrell Hatton, Tommy Fleetwood, Jon Rahm, Rory McIlroy, Alex Noren, Thorbjorn Olesen, Paul Casey, Sergio Garcia, Ian Poulter, Henrik Stenson
USA:
Brooks Koepka, Justin Thomas, Dustin Johnson, Patrick Reed, Bubba Watson, Jordan Spieth, Rickie Fowler, Webb Simpson, Tiger Woods, Phil Mickelson, Bryson DeChambeau ( 1 TBC)
Student Of The Year 2
Director: Punit Malhotra
Stars: Tiger Shroff, Tara Sutaria, Ananya Pandey, Aditya Seal
1.5 stars
The story in numbers
18
This is how many recognised sects Lebanon is home to, along with about four million citizens
450,000
More than this many Palestinian refugees are registered with UNRWA in Lebanon, with about 45 per cent of them living in the country’s 12 refugee camps
1.5 million
There are just under 1 million Syrian refugees registered with the UN, although the government puts the figure upwards of 1.5m
73
The percentage of stateless people in Lebanon, who are not of Palestinian origin, born to a Lebanese mother, according to a 2012-2013 study by human rights organisation Frontiers Ruwad Association
18,000
The number of marriages recorded between Lebanese women and foreigners between the years 1995 and 2008, according to a 2009 study backed by the UN Development Programme
77,400
The number of people believed to be affected by the current nationality law, according to the 2009 UN study
4,926
This is how many Lebanese-Palestinian households there were in Lebanon in 2016, according to a census by the Lebanese-Palestinian dialogue committee
UAE currency: the story behind the money in your pockets
UAE currency: the story behind the money in your pockets
