The Emirati Ministry of Finance May 10 posted online Ministerial Decision No. 116/2023, clarifying the tax exemption on qualifying participation shares. The decision includes: 1) rules for determining, aggregating, and transferring ownership interests in participation shares; 2) taxation and exemption of dividends and capital gains from qualifying participation shares; 3) application of the exemption to nonresidents, for covered income subject to aggregate tax rates of at least 9 percent; 4) application of the exemption when total acquisition costs exceed 4 million Emirati dirhams (US$1.1 million); 5) the requirement that foreign permanent establishments (PEs) offset tax losses against participation share income, ...
