UAE: Updated guidance on participation exemption and foreign permanent establishment exemption

Guidance applies for tax periods beginning on or after January 1, 2025

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February 4, 2025

The Ministry of Finance (MoF) issued an updated Ministerial Decision No. 302 of 2024 on the participation exemption and foreign permanent establishment (PE) exemption, which replaces Ministerial Decision No. 116 of 2023 and applies for tax periods beginning on or after January 1, 2025.

Key amendments under the updated guidance relate to:

  • Definitions
  • Minimum acquisition cost
  • Application of the asset test
  • Transfer of ownership interest
  • Liquidation proceeds and losses
  • Foreign PE exemption

Read a February 2025 report prepared by the KPMG member firm in the UAE

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