This decision clarifies the tax status of an Unincorporated Partnership that elects to be treated as a Taxable Person, per Clause (8) of Article 16 of the Corporate Tax Law. Upon submitting an application and receiving approval from the Federal Tax Authority (FTA), the partnership is legally deemed to be both a juridical person and a Resident Person for all purposes of the Corporate Tax Law. This legally establishes the partnership as a distinct entity for tax purposes, subjecting it to the standard corporate tax framework. The decision is effective from 1 June 2023.
This is not an Official Translation:
Unincorporated Partnership That is Treated as a Taxable Person in Its Own Right for the Purposes of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses
Cabinet Decision No. 63 of 2025
Issued 14 May 2025 - (Effective from 1 Jun 2023)
The Cabinet:
Having reviewed the Constitution,
Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses, and its amendments,
Pursuant to what was presented by the Minister of Finance and upon the approval of the Cabinet,
Decided:
Article 1 - Definitions
Definitions in Federal Decree-Law No. 47 of 2022 referred to above shall apply to this Decision.
Article 2 - The Implications of Treating an Unincorporated Partnership as a Taxable Person in Its Own Right
Where the Authority approves an application made by the partners in an Unincorporated Partnership under Clause (8) of Article 16 of Federal Decree-Law No. 47 of 2022 referred to above to treat the Unincorporated Partnership as a Taxable Person in its own right, the Unincorporated Partnership shall be considered a juridical person and a Resident Person for the purposes of the aforementioned Corporate Tax Law.
Article 3 - Publication and Application of the Decision
This Decision shall be published in the Official Gazette and shall be effective from 1 June 2023.
Mohammed bin Rashid Al Maktoum
Prime Minister
Issued by us:
On: 16 / Dhuʻl-Qiʻdah / 1446H Corresponding to: 14 / May / 2025
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