UAE Corporate Tax Consultancy, Written Opinions from partnered tax professionals
Not every CT question needs a full return filing engagement. Sometimes you need a clear, documented answer to one specific question before you sign a contract, restructure, or make a business decision. We provide written CT opinions on specific transactions and technical questions, from AED 1,000 per engagement.
When You Need UAE CT Consultancy
UAE Corporate Tax law contains significant complexity around entity classification, exempt income, QFZP conditions, related-party treatment, and transitional rules for businesses formed before June 2023. A wrong classification or missed exemption condition can mean paying 9% on income that should have been exempt, or claiming an exemption you were not entitled to and facing an FTA adjustment. CT consultancy engagements provide a documented, legally referenced position on the specific question before the decision is made.
| Question or Scenario | Why CT Advice Helps |
|---|---|
| Entity classification (natural person vs juridical person) | CT treatment differs significantly |
| Dividend or capital gain from subsidiary | Participation exemption eligibility |
| Foreign income received by UAE entity | Taxable in UAE or foreign tax credit available |
| Pre-June 2023 assets (transitional rules) | Opening balance and gain calculation |
| FTA audit query received | Technical response preparation |
| Industry-specific CT treatment | Real estate, financial services, insurance, extractives |
Source: UAE Corporate Tax Law, Federal Decree-Law No. 47 of 2022. FTA Corporate Tax Guides and Public Clarifications 2023 to 2026.
How a CT Consultancy Engagement Works
Question Scoping and Fee Confirmation
You describe the transaction, decision, or FTA query you need an opinion on. We assess the complexity, identify the applicable legislative provisions, and confirm a fixed fee before starting. For FTA audit responses, we review the FTA query letter and confirm the scope of our response support.
Research and Opinion Preparation
We research the applicable UAE CT Law provisions, FTA Corporate Tax Guides, Cabinet Decisions, and Ministerial Decisions relevant to your question. We prepare a written opinion that states the applicable rules, our conclusion, the conditions required to support that conclusion, and the risks if the FTA takes a different view.
Delivery and Implementation Guidance
You receive a written CT opinion in PDF format, referenced to specific legal articles and FTA guidance. Where the opinion supports a particular position, we also provide the documentation required to support it. For ongoing transactions, we advise on how the position should be reflected in your bookkeeping and CT return.
Fixed Fee Per Engagement.
Fee confirmed before work starts. No hourly billing, no scope creep.
Transaction CT Opinion
- ✓Single transaction or question
- ✓Written CT opinion with legal references
- ✓Risk assessment included
- ✓Documentation requirements listed
- ✓Delivered within 5 business days
Complex Advisory or Audit Support
- ✓Multi-issue technical advisory
- ✓FTA audit query response preparation
- ✓FTA Private Clarification application
- ✓Voluntary Disclosure preparation
- ✓Ongoing retainer available
FTA audit adjustment on misclassified income: 9% of the adjusted amount plus late payment penalties. A documented opinion before the decision is always cheaper than correcting it after.
Why CalcUAE for CT Consultancy
Written, Referenced Opinions
Every opinion cites the specific legal article and FTA guidance it is based on. That document is your evidence of due diligence in any future FTA interaction.
partnered tax professionals
We can make FTA Private Clarification applications on your behalf where the law is genuinely ambiguous, providing a formal FTA position with legal protection.
Honest Risk Assessment
Where a position is arguable but not certain, we say so. We also present the FTA's likely counter-position and the penalty exposure if they take it.
Audit Response Support
If you receive an FTA audit query, we prepare the technical response, compile the supporting documentation, and correspond with the FTA on your behalf.
UAE CT Consultancy: Common Questions
What is the participation exemption under UAE CT?
The participation exemption under UAE Corporate Tax Law, Article 23, exempts dividends and capital gains received by a UAE entity from a subsidiary from Corporate Tax, subject to conditions. The subsidiary must be a juridical person (not a natural person), the UAE entity must hold at least 5% of the shares, the investment must have been held for at least 12 months, and the subsidiary must not be resident in a jurisdiction with a CT rate below 9%. The exemption also applies to foreign permanent establishments if elected. Assessing whether a dividend or disposal qualifies requires checking each condition against the specific subsidiary.
Is income from a foreign branch taxable in the UAE?
A UAE company's foreign branch income is included in the UAE taxable income by default. However, UAE CT Law, Article 24, allows an entity to elect to exempt its foreign permanent establishment income from UAE CT if the foreign jurisdiction taxes the income at a rate of at least 9%. The election is irrevocable and applies to all foreign PEs. If the election is not made, a Foreign Tax Credit is available to offset the UAE CT liability by the foreign tax paid. The better option depends on the foreign tax rate and the entity's overall position.
How are pre-June 2023 assets treated for UAE CT purposes?
Assets and liabilities held before the start of the first CT tax period have transitional rules under Ministerial Decision No. 116 of 2023. For assets not held on capital account (trading stock), the normal CT rules apply from day one. For capital assets (property, shares, investments), the entity can elect to use the market value at the start of its first CT period as the opening cost for CT purposes. This means gains accrued before CT applied are not taxed. The election must be made in the first CT return and is irrevocable. Missing this election means pre-CT gains are included in taxable income on disposal.
What is a Voluntary Disclosure and when should I file one?
A Voluntary Disclosure (VD) is a self-correction mechanism that allows a CT taxpayer to correct errors in a previously filed return. The VD penalty under Cabinet Decision No. 75 of 2023 is 1% of the underpaid tax per month if filed before an FTA audit. If the FTA identifies the error first, the penalty rises to 50% of the underpaid tax plus interest. Filing a VD is always better than waiting for the FTA to find the error. We assess whether a VD is required and prepare the submission on EmaraTax.
Does CT apply to sole proprietorships and natural persons in UAE?
Natural persons are subject to UAE CT only if they conduct a business or business activity that generates income exceeding AED 1 million in a calendar year. Below AED 1 million, natural persons are outside the CT scope entirely. Employment income, investment income (dividends, interest on personal savings), and income from personal property are excluded from the AED 1 million threshold. Only business income counts. Sole proprietors with revenue above AED 1 million must register for CT and file annual returns.
Get a Written CT Opinion Before You Make the Decision
WhatsApp us the question. We confirm the fee and turnaround before starting. From AED 1,000.
WhatsApp +971 55 963 0486