OpenAI, the company leading the generative artificial intelligence boom, is considering a shift in its structure to create a for-profit corporation alongside its non-profit unit.
The company plans to change its existing for-profit arm into a public benefit corporation (PBC), incorporated in Delaware, with ordinary shares of stock, it said in a blog post on Friday.
The PBC will run and control OpenAI’s operations and business, while the non-profit will hire a leadership team and staff to pursue charitable initiatives in sectors such as health care, education and science.
The company's current structure does not allow the board to "directly consider the interests of those who would finance the mission and does not enable the non-profit to easily do more than control the for-profit", it said.
However, its shift will enable it to raise the necessary capital on conventional terms, like others in the space, OpenAI said.
OpenAI, which started in 2015 as a research-focused non-profit, says that its mission is to ensure that AI is of benefit to humanity.
Its ChatGPT platform is a generative AI chatbot that provides human-like responses to prompts in seconds, based on information publicly available on the internet. The technology has become hugely popular since its launch in December 2022 and is currently used by 300 million people each week, according to OpenAI.
However, the company, which is backed by Microsoft, is seeking to boost investments as it rapidly scales its AI offering.
In October, the company raised $6.6 billion in new funding, giving it a valuation of $157 billion. OpenAI said it would use the cash influx to drive forward AI research and increase its computing capacity.
The round was led by Thrive Capital, which put in $1.3 billion, with Microsoft, Khosla Ventures, Fidelity Management and Research, Nvidia, Tiger Global Management, SoftBank and Altimeter Capital among other investors, Bloomberg reported at the time.
"We once again need to raise more capital than we'd imagined. Investors want to back us but, at this scale of capital, need conventional equity and less structural bespokeness," OpenAI said.
At present, the company's competitors, including AI start-up Anthropic and Elon Musk-owned xAI, use a similar corporate structure.
Mr Musk, who co-founded OpenAI in 2015, had a falling out with the start-up. He also sued OpenAI and its chief executive Sam Altman in February, alleging it abandoned its initial non-profit mission and called the company “a lie”.
Although the Tesla founder withdrew the lawsuit in June, he filed another one in August, arguing that the AI company put profits ahead of the public good.
In the new lawsuit, first reported by The New York Times, Mr Musk alleged that once the company's technology started to transform generative AI, Mr Altman “flipped the narrative and proceeded to cash in”.
OpenAI has a licensing partnership with Microsoft, with the tech company investing billions of dollars into the AI start-up in exchange for use of its large language models for its computing services.
Mr Musk contends that OpenAI's language models are outside the scope of the company's partnership with Microsoft. The lawsuit seeks a judicial decision rendering the company's licence to Microsoft null and void.
OpenAI, meanwhile, has said that Mr Musk is just regretful that he wasn't part of the company's success.
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Family: Parents and four sisters
Education: Bachelor’s degree in business management and marketing at American University of Sharjah
A self-confessed foodie, she enjoys trying out new cuisines, her current favourite is the poke superfood bowls
Likes reading: autobiographies and fiction
Favourite holiday destination: Italy
Posts information about challenges, events, runs in other emirates on the group's Instagram account @Anagowrunning
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Apart from training, also talks to women about nutrition, healthy lifestyle, diabetes, cholesterol, blood pressure
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Ten tax points to be aware of in 2026
1. Domestic VAT refund amendments: request your refund within five years
If a business does not apply for the refund on time, they lose their credit.
2. E-invoicing in the UAE
Businesses should continue preparing for the implementation of e-invoicing in the UAE, with 2026 a preparation and transition period ahead of phased mandatory adoption.
3. More tax audits
Tax authorities are increasingly using data already available across multiple filings to identify audit risks.
4. More beneficial VAT and excise tax penalty regime
Tax disputes are expected to become more frequent and more structured, with clearer administrative objection and appeal processes. The UAE has adopted a new penalty regime for VAT and excise disputes, which now mirrors the penalty regime for corporate tax.
5. Greater emphasis on statutory audit
There is a greater need for the accuracy of financial statements. The International Financial Reporting Standards standards need to be strictly adhered to and, as a result, the quality of the audits will need to increase.
6. Further transfer pricing enforcement
Transfer pricing enforcement, which refers to the practice of establishing prices for internal transactions between related entities, is expected to broaden in scope. The UAE will shortly open the possibility to negotiate advance pricing agreements, or essentially rulings for transfer pricing purposes.
7. Limited time periods for audits
Recent amendments also introduce a default five-year limitation period for tax audits and assessments, subject to specific statutory exceptions. While the standard audit and assessment period is five years, this may be extended to up to 15 years in cases involving fraud or tax evasion.
8. Pillar 2 implementation
Many multinational groups will begin to feel the practical effect of the Domestic Minimum Top-Up Tax (DMTT), the UAE's implementation of the OECD’s global minimum tax under Pillar 2. While the rules apply for financial years starting on or after January 1, 2025, it is 2026 that marks the transition to an operational phase.
9. Reduced compliance obligations for imported goods and services
Businesses that apply the reverse-charge mechanism for VAT purposes in the UAE may benefit from reduced compliance obligations.
10. Substance and CbC reporting focus
Tax authorities are expected to continue strengthening the enforcement of economic substance and Country-by-Country (CbC) reporting frameworks. In the UAE, these regimes are increasingly being used as risk-assessment tools, providing tax authorities with a comprehensive view of multinational groups’ global footprints and enabling them to assess whether profits are aligned with real economic activity.
Contributed by Thomas Vanhee and Hend Rashwan, Aurifer
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