Further to the UAE Federal Tax Authority (FTA) decision no. 3 of 2024 (the Decision) specifying the timelines for the submission of corporate tax (CT) registration applications by taxable persons, the FTA has recently issued a CT public clarification (CTP001) explaining, with examples, the registration timelines applicable to different taxable persons.

The keys aspects of the said public clarification are highlighted below:

• All taxable persons are required to submit a CT registration application no later than the timelines set out in the Decision.
• The timelines specified in the Decision apply to a juridical person whose first tax period has already begun, irrespective of the person intending to cease, or having ceased, business activities, or liquidating after the start of its first tax period
• The requirement to submit a CT registration applies also to ‘’free zone offshore companies’’ that are incorporated, or otherwise established or recognized, under the applicable legislation in the UAE.
• Where a juridical person holds a licence as at 1 March 2024 that has expired but has not yet been cancelled, it must submit a CT registration application by reference to the month of its original licence issuance.
• Where a juridical person holds more than one licence as at 1 March 2024, it should use the licence with the earliest issuance date when determining the deadline by which it should submit the CT registration application.
• A foreign entity that is effectively managed and controlled in the UAE prior to 1 March 2024 must submit a CT registration application within three months from the effective date of the Decision, i.e., by 31 May 2024. Such an entity is categorized as a resident person under the CT law.
• With reference to deadline for submission of CT registration applicable to a non-resident person, the date of “existence of a permanent establishment” is when the permanent establishment is recognized for UAE CT purposes.¹
• If an international agreement for the avoidance of double taxation provides for a longer duration to recognize a permanent establishment in the UAE than the CT law, the provision in the international agreement will prevail.
• It is reiterated that failure to submit a CT registration application within the specified timeline will result in an administrative penalty of AED 10,000.

1 In accordance with the Decision, the deadline for submitting a CT registration application is (i) 9 months from the date of existence of the permanent establishment for a juridical person that is a non-resident person prior to 1 March 2024; and (ii) 6 months from the date of existence of the permanent establishment for a juridical person that is a non- resident person on or after 1 March 2024.