Business Insights
- As per the document, there are six filing options, including choosing to report on a realisation basis and transitional rules for pre-tax period gains or losses.
- SMEs with revenue below Dh3 million per annum can opt for transitional relief until 2026, treating them as having no taxable income.
- Larger entities have specific provisions for asset and liability movements, business restructuring, and handling foreign permanent establishments.
Increased clarity on the corporate tax preparation and filing process in the UAE was something I was keenly anticipating.
To put it in context, after gaining independence, Estonia introduced a one-page tax return for everyone. There was little technical knowledge to absorb and what excuse could you have for a form that a child could complete?
I had hoped we might get something similar (although not quite the same, as the world is different today), which would act as a launching pad for additional nuance to be added. This would allow us to ease into international normality.
Corporate tax guide CTGTXR1 was released this month by the Federal Tax Authority. The lengthy document, which has the normal warning that it is for guidance and education only, is a must read.
There cannot be a comprehensive guide for every possibility, so do not expect one. The nuances are close to infinity. What we have must be warmly welcomed. Unfortunately, for you the reader, its length means I will only be able to briefly summarise its contents.
Many hours of study await you, as you match your business’s financials to the reporting framework. Also, it is not only the quantity of screens you need to move through and complete: there are often requirements to produce and attach supporting schedules, both numerical and verbal.
You do not need to do this alone, and so do not be afraid of seeking help.
Since it is topical, let us start with elections. These are choices you get to make from a list of presented options where you choose the candidate(s) that will deliver what you want. Ballots are in many ways by their nature an act of selfishness. Why select something that will cause harm or be suboptimal in the face of a better outcome?
Coming to back to CTGTXR1, there are six options when it comes to filing returns. For the first time, all of them should be available to select. In future returns, the choices you make now may mean that they do not appear or may not appear for several years.
First up is choosing to report on a realisation basis. This deals specifically with gains or losses on the disposal of assets or when a liability is settled. Whatever direction you choose here is permanent. Yes, you may appeal to the Federal Tax Authority in the future, but the circumstances would need to be extraordinary.
Additionally, the factors impact that decision will probably evolve, so any current strategic thinking may go out of date before it can be acted on.
Next come transitional rules. These permit the exclusion of gains or losses relating to the time before your first corporate tax reporting period. However, this only applies to qualifying financial assets and liabilities.
A critical element of qualifying involves recording immovable property (think buildings and intangible assets) as well as brands on a historical cost basis (referring to the value that was paid for the asset at the time of acquisition).
After this comes the option that will apply to many small and medium enterprises in the UAE. Residents who are not in qualifying free zones or members of a multinational group, and whose revenue is below Dh3 million for the reporting period, can elect to be treated as if they derive no taxable income.
This is a limited-time transitional relief to support the SME sector and is valid only until 2026. So, mark that date.
For larger and more complicated entities, there is a special allowable asset and liability movement, as long as the group qualifies. It applies to the entity that makes the transfer and carries into the future when there are further balance sheet transfers within the qualifying group.
Next comes business restricting relief. The uniqueness here is that it involves the transfer of a business or independent part thereof to another taxable person. This is completed at par value, so no losses or gains accrue to the movement and no corporate tax is payable.
Finally comes moving a UAE resident’s foreign permanent establishment(s) from the purview of UAE corporate tax. It’s an all or nothing choice. Both revenue and costs are excluded.
Wicked: For Good
Director: Jon M Chu
Starring: Ariana Grande, Cynthia Erivo, Jonathan Bailey, Jeff Goldblum, Michelle Yeoh, Ethan Slater
Rating: 4/5
While you're here
Hussein Ibish: The George Floyd tragedy is a turning point for America
Colin Randall: In France, police violence isn't a black-and-white issue
World Cricket League Division 2
In Windhoek, Namibia - Top two teams qualify for the World Cup Qualifier in Zimbabwe, which starts on March 4.
UAE fixtures
Thursday February 8, v Kenya; Friday February 9, v Canada; Sunday February 11, v Nepal; Monday February 12, v Oman; Wednesday February 14, v Namibia; Thursday February 15, final
MATCH INFO
Everton 2 Southampton 1
Everton: Walcott (15'), Richarlison (31' )
Southampton: Ings (54')
Man of the match: Theo Walcott (Everton)
While you're here
The National Editorial: The fragile future of jobs in the Middle East
Daniel Bardsley: Covid-19 effect on jobs – the occupations most at risk
Alice Haine: Sunak urged to rescue ailing car industry as production slumps
While you're here
Chitrabhanu Kadalayil: Singapore election is more than just a family feud over LKY's legacy
Sholto Byrnes: Robert Mugabe and Lee Kuan Yew: two leaders with very different legacies
Dr Vivian Balakrishnan: UAE and Singapore can be partners for a world in transition
Nick March: Singapore and UAE are on the move – in airport development
MISSION: IMPOSSIBLE – FINAL RECKONING
Director: Christopher McQuarrie
Starring: Tom Cruise, Hayley Atwell, Simon Pegg
Rating: 4/5
While you're here
Johann Chacko: Why Maldives has become a theatre for US-China rivalry
C Uday Bhaskar: What is India's Indo-Pacific strategy?
C Uday Bhaskar: The 'Asian Century' depends on China and India working together
ENGLAND SQUAD
Team: 15 Mike Brown, 14 Anthony Watson, 13 Ben Te'o, 12 Owen Farrell, 11 Jonny May, 10 George Ford, 9 Ben Youngs, 1 Mako Vunipola, 2 Dylan Hartley, 3 Dan Cole, 4 Joe Launchbury, 5 Maro Itoje, 6 Courtney Lawes, 7 Chris Robshaw, 8 Sam Simmonds
Replacements 16 Jamie George, 17 Alec Hepburn, 18 Harry Williams, 19 George Kruis, 20 Sam Underhill, 21 Danny Care, 22 Jonathan Joseph, 23 Jack Nowell
The Meg
Director: Jon Turteltaub
Starring: Jason Statham, Bingbing Li, Rainn Wilson
Two stars
ZAYED SUSTAINABILITY PRIZE
How to apply for a drone permit
- Individuals must register on UAE Drone app or website using their UAE Pass
- Add all their personal details, including name, nationality, passport number, Emiratis ID, email and phone number
- Upload the training certificate from a centre accredited by the GCAA
- Submit their request
What are the regulations?
- Fly it within visual line of sight
- Never over populated areas
- Ensure maximum flying height of 400 feet (122 metres) above ground level is not crossed
- Users must avoid flying over restricted areas listed on the UAE Drone app
- Only fly the drone during the day, and never at night
- Should have a live feed of the drone flight
- Drones must weigh 5 kg or less
Recommended
Women are on the front line of the coronavirus fight, and we should all remember that by Phumzile Mlambo-Ngcuka
Coronavirus: How the world can end the pandemic by Bill Gates
Famine on the rise in the Middle East and North Africa
Inside the UN's Dubai aid facility delivering support to people in need across the globe
Common OCD symptoms and how they manifest
Checking: the obsession or thoughts focus on some harm coming from things not being as they should, which usually centre around the theme of safety. For example, the obsession is “the building will burn down”, therefore the compulsion is checking that the oven is switched off.
Contamination: the obsession is focused on the presence of germs, dirt or harmful bacteria and how this will impact the person and/or their loved ones. For example, the obsession is “the floor is dirty; me and my family will get sick and die”, the compulsion is repetitive cleaning.
Orderliness: the obsession is a fear of sitting with uncomfortable feelings, or to prevent harm coming to oneself or others. Objectively there appears to be no logical link between the obsession and compulsion. For example,” I won’t feel right if the jars aren’t lined up” or “harm will come to my family if I don’t line up all the jars”, so the compulsion is therefore lining up the jars.
Intrusive thoughts: the intrusive thought is usually highly distressing and repetitive. Common examples may include thoughts of perpetrating violence towards others, harming others, or questions over one’s character or deeds, usually in conflict with the person’s true values. An example would be: “I think I might hurt my family”, which in turn leads to the compulsion of avoiding social gatherings.
Hoarding: the intrusive thought is the overvaluing of objects or possessions, while the compulsion is stashing or hoarding these items and refusing to let them go. For example, “this newspaper may come in useful one day”, therefore, the compulsion is hoarding newspapers instead of discarding them the next day.
Source: Dr Robert Chandler, clinical psychologist at Lighthouse Arabia
The specs
Engine: 4-litre twin-turbo V8
Transmission: nine-speed
Power: 542bhp
Torque: 700Nm
Price: Dh848,000
On sale: now
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While you're here
Samanth Subramanian: Imposing Hindi could undermine India's linguistic diversity
Phil Mercer: Aboriginal musicians are struggling to be heard
Gavin Esler: What we lose when we allow languages to die
McLaren GT specs
Engine: 4-litre twin-turbo V8
Transmission: seven-speed
Power: 620bhp
Torque: 630Nm
Price: Dh875,000
On sale: now
New schools in Dubai
Tomorrow 2021
Opinions on Lebanon
Kareem Shaheen: Lebanon is being forced to relive its traumas
Michael Young: Hezbollah is losing its ability to intimidate anyone
Raghida Dergham: Lebanon-Israel talks will mark another win for Donald Trump
Company Profile
Name: JustClean
Based: Kuwait with offices in other GCC countries
Launch year: 2016
Number of employees: 130
Sector: online laundry service
Funding: $12.9m from Kuwait-based Faith Capital Holding
While you're here
RESULT
Aston Villa 1
Samatta (41')
Manchester City 2
Aguero (20')
Rodri (30')
The specs: 2018 Chevrolet Trailblazer
Price, base / as tested Dh99,000 / Dh132,000
Engine 3.6L V6
Transmission: Six-speed automatic
Power 275hp @ 6,000rpm
Torque 350Nm @ 3,700rpm
Fuel economy combined 12.2L / 100km
While you're here
Super Rugby play-offs
Quarter-finals
- Hurricanes 35, ACT 16
- Crusaders 17, Highlanders 0
- Lions 23, Sharks 21
- Chiefs 17, Stormers 11
Semi-finals
Saturday, July 29
- Crusaders v Chiefs, 12.35pm (UAE)
- Lions v Hurricanes, 4.30pm
The burning issue
The internal combustion engine is facing a watershed moment – major manufacturer Volvo is to stop producing petroleum-powered vehicles by 2021 and countries in Europe, including the UK, have vowed to ban their sale before 2040. The National takes a look at the story of one of the most successful technologies of the last 100 years and how it has impacted life in the UAE.
Read part four: an affection for classic cars lives on
Read part three: the age of the electric vehicle begins
Read part two: how climate change drove the race for an alternative
Lowest Test scores
26 - New Zealand v England at Auckland, March 1955
30 - South Africa v England at Port Elizabeth, Feb 1896
30 - South Africa v England at Birmingham, June 1924
35 - South Africa v England at Cape Town, April 1899
36 - South Africa v Australia at Melbourne, Feb. 1932
36 - Australia v England at Birmingham, May 1902
36 - India v Australia at Adelaide, Dec. 2020
38 - Ireland v England at Lord's, July 2019
42 - New Zealand v Australia in Wellington, March 1946
42 - Australia v England in Sydney, Feb. 1888
The specs
Engine: 4-litre twin-turbo V8
Transmission: eight-speed PDK
Power: 630bhp
Torque: 820Nm
Price: Dh683,200
On sale: now
While you're here
Joyce Karam: Chaotic first debate unlikely to swing undecideds
Hussein Ibish: Donald Trump's 3-step plan to cling to power
Sulaiman Hakemy: Make America lose again
On Women's Day
Shelina Janmohamed: Why shouldn't a spouse be compensated fairly for housework?
Samar Elmnhrawy: How companies in the Middle East can catch up on gender equality
The National Editorial: Is there much to celebrate on International Women's Day 2021?
Justin Thomas: Challenge the notion that 'men are from Mars, women are from Venus'
What is a robo-adviser?
Robo-advisers use an online sign-up process to gauge an investor’s risk tolerance by feeding information such as their age, income, saving goals and investment history into an algorithm, which then assigns them an investment portfolio, ranging from more conservative to higher risk ones.
These portfolios are made up of exchange traded funds (ETFs) with exposure to indices such as US and global equities, fixed-income products like bonds, though exposure to real estate, commodity ETFs or gold is also possible.
Investing in ETFs allows robo-advisers to offer fees far lower than traditional investments, such as actively managed mutual funds bought through a bank or broker. Investors can buy ETFs directly via a brokerage, but with robo-advisers they benefit from investment portfolios matched to their risk tolerance as well as being user friendly.
Many robo-advisers charge what are called wrap fees, meaning there are no additional fees such as subscription or withdrawal fees, success fees or fees for rebalancing.
Superliminal%20
Explainer: Tanween Design Programme
Non-profit arts studio Tashkeel launched this annual initiative with the intention of supporting budding designers in the UAE. This year, three talents were chosen from hundreds of applicants to be a part of the sixth creative development programme. These are architect Abdulla Al Mulla, interior designer Lana El Samman and graphic designer Yara Habib.
The trio have been guided by experts from the industry over the course of nine months, as they developed their own products that merge their unique styles with traditional elements of Emirati design. This includes laboratory sessions, experimental and collaborative practice, investigation of new business models and evaluation.
It is led by British contemporary design project specialist Helen Voce and mentor Kevin Badni, and offers participants access to experts from across the world, including the likes of UK designer Gareth Neal and multidisciplinary designer and entrepreneur, Sheikh Salem Al Qassimi.
The final pieces are being revealed in a worldwide limited-edition release on the first day of Downtown Designs at Dubai Design Week 2019. Tashkeel will be at stand E31 at the exhibition.
Lisa Ball-Lechgar, deputy director of Tashkeel, said: “The diversity and calibre of the applicants this year … is reflective of the dynamic change that the UAE art and design industry is witnessing, with young creators resolute in making their bold design ideas a reality.”
Sholto Byrnes on Myanmar politics
Turkish Ladies
Various artists, Sony Music Turkey
Zayed Sustainability Prize
While you're here
National Editorial: What 'Fight Island' means for Abu Dhabi and the world
National Editorial: The UAE looks to cycling for exercise and for the planet
Gareth Cox: Sporting week in pictures, as Covid-19 makes its presence felt
UAE central contracts
Full time contracts
Rohan Mustafa, Ahmed Raza, Mohammed Usman, Chirag Suri, Mohammed Boota, Sultan Ahmed, Zahoor Khan, Junaid Siddique, Waheed Ahmed, Zawar Farid
Part time contracts
Aryan Lakra, Ansh Tandon, Karthik Meiyappan, Rahul Bhatia, Alishan Sharafu, CP Rizwaan, Basil Hameed, Matiullah, Fahad Nawaz, Sanchit Sharma
Results:
6.30pm: Handicap (Turf) | US$175,000 2,410m | Winner: Bin Battuta, Christophe Soumillon (jockey), Saeed bin Suroor (trainer)
7.05pm: UAE 1000 Guineas Trial Conditions (Dirt) | $100,000 | 1,400m | Winner: Al Hayette, Fabrice Veron, Ismail Mohammed
7.40pm: Handicap (T) | $145,000 | 1,000m | Winner: Faatinah, Jim Crowley, David Hayes
8.15pm: Dubawi Stakes Group 3 (D) | $200,000 | 1,200m | Winner: Raven’s Corner, Richard Mullen, Satish Seemar
8.50pm: Singspiel Stakes Group 3 (T) | $200,000 | 1,800m | Winner: Dream Castle, Christophe Soumillon, Saeed bin Suroor
9.25pm: Handicap (T) | $175,000 | 1,400m | Winner: Another Batt, Connor Beasley, George Scott
Dhadak 2
Director: Shazia Iqbal
Starring: Siddhant Chaturvedi, Triptii Dimri
Rating: 1/5
About Krews
Founder: Ahmed Al Qubaisi
Based: Abu Dhabi
Founded: January 2019
Number of employees: 10
Sector: Technology/Social media
Funding to date: Estimated $300,000 from Hub71 in-kind support
Our legal columnist
Name: Yousef Al Bahar
Advocate at Al Bahar & Associate Advocates and Legal Consultants, established in 1994
Education: Mr Al Bahar was born in 1979 and graduated in 2008 from the Judicial Institute. He took after his father, who was one of the first Emirati lawyers
Islamophobia definition
A widely accepted definition was made by the All Party Parliamentary Group on British Muslims in 2019: “Islamophobia is rooted in racism and is a type of racism that targets expressions of Muslimness or perceived Muslimness.” It further defines it as “inciting hatred or violence against Muslims”.
Pope Francis in UAE
LIST OF INVITEES
Shergo Kurdi (am)
Rayhan Thomas
Saud Al Sharee (am)
Min Woo Lee
Todd Clements
Matthew Jordan
AbdulRahman Al Mansour (am)
Matteo Manassero
Alfie Plant
Othman Al Mulla
Shaun Norris
What vitamins do we know are beneficial for living in the UAE
Vitamin D: Highly relevant in the UAE due to limited sun exposure; supports bone health, immunity and mood.
Vitamin B12: Important for nerve health and energy production, especially for vegetarians, vegans and individuals with absorption issues.
Iron: Useful only when deficiency or anaemia is confirmed; helps reduce fatigue and support immunity.
Omega-3 (EPA/DHA): Supports heart health and reduces inflammation, especially for those who consume little fish.
The biog:
Languages: Arabic, Farsi, Hindi, basic Russian
Favourite food: Pizza
Best food on the road: rice
Favourite colour: silver
Favourite bike: Gold Wing, Honda
Favourite biking destination: Canada
The specs: 2019 Mercedes-Benz C200 Coupe
Price, base: Dh201,153
Engine: 2.0-litre turbocharged four-cylinder
Transmission: Nine-speed automatic
Power: 204hp @ 5,800rpm
Torque: 300Nm @ 1,600rpm
Fuel economy, combined: 6.7L / 100km
The National photo project
Chris Whiteoak, a photographer at The National, spent months taking some of Jacqui Allan's props around the UAE, positioning them perfectly in front of some of the country's most recognisable landmarks. He placed a pirate on Kite Beach, in front of the Burj Al Arab, the Cheshire Cat from Alice in Wonderland at the Burj Khalifa, and brought one of Allan's snails (Freddie, which represents her grandfather) to the Dubai Frame. In Abu Dhabi, a dinosaur went to Al Ain's Jebel Hafeet. And a flamingo was taken all the way to the Hatta Mountains. This special project suitably brings to life the quirky nature of Allan's prop shop (and Allan herself!).
The national orchestra
COMPANY PROFILE
Company name: SimpliFi
Started: August 2021
Founder: Ali Sattar
Based: UAE
Industry: Finance, technology
Investors: 4DX, Rally Cap, Raed, Global Founders, Sukna and individuals
Premier League results
Saturday
Tottenham Hotspur 1 Arsenal 1
Bournemouth 0 Manchester City 1
Brighton & Hove Albion 1 Huddersfield Town 0
Burnley 1 Crystal Palace 3
Manchester United 3 Southampton 2
Wolverhampton Wanderers 2 Cardiff City 0
West Ham United 2 Newcastle United 0
Sunday
Watford 2 Leicester City 1
Fulham 1 Chelsea 2
Everton 0 Liverpool 0
Match info
Costa Rica 0
Serbia 1
Kolarov (56')
Cracks in the Wall
Ben White, Pluto Press
Specs
Price, base: Dhs850,000
Engine: 3.9-litre twin-turbo V8
Transmission: Seven-speed automatic
Power: 591bhp @ 7,500rpm
Torque: 760Nm @ 3,000rpm
Fuel economy, combined: 11.3L / 100km
The specs: 2018 Maserati Levante S
Price, base / as tested: Dh409,000 / Dh467,000
Engine: 3.0-litre V6
Transmission: Eight-speed automatic
Power: 430hp @ 5,750rpm
Torque: 580Nm @ 4,500rpm
Fuel economy, combined: 10.9L / 100km
New schools in Dubai
More from this package
How green is the expo nursery?
Some 400,000 shrubs and 13,000 trees in the on-site nursery
An additional 450,000 shrubs and 4,000 trees to be delivered in the months leading up to the expo
Ghaf, date palm, acacia arabica, acacia tortilis, vitex or sage, techoma and the salvadora are just some heat tolerant native plants in the nursery
Approximately 340 species of shrubs and trees selected for diverse landscape
The nursery team works exclusively with organic fertilisers and pesticides
All shrubs and trees supplied by Dubai Municipality
Most sourced from farms, nurseries across the country
Plants and trees are re-potted when they arrive at nursery to give them room to grow
Some mature trees are in open areas or planted within the expo site
Green waste is recycled as compost
Treated sewage effluent supplied by Dubai Municipality is used to meet the majority of the nursery’s irrigation needs
Construction workforce peaked at 40,000 workers
About 65,000 people have signed up to volunteer
Main themes of expo is ‘Connecting Minds, Creating the Future’ and three subthemes of opportunity, mobility and sustainability.
Expo 2020 Dubai to open in October 2020 and run for six months
SUZUME
Strait of Hormuz
Fujairah is a crucial hub for fuel storage and is just outside the Strait of Hormuz, a vital shipping route linking Middle East oil producers to markets in Asia, Europe, North America and beyond.
The strait is 33 km wide at its narrowest point, but the shipping lane is just three km wide in either direction. Almost a fifth of oil consumed across the world passes through the strait.
Iran has repeatedly threatened to close the strait, a move that would risk inviting geopolitical and economic turmoil.
Last month, Iran issued a new warning that it would block the strait, if it was prevented from using the waterway following a US decision to end exemptions from sanctions for major Iranian oil importers.
UAE Premiership
Results
Dubai Exiles 24-28 Jebel Ali Dragons
Abu Dhabi Harlequins 43-27 Dubai Hurricanes
Final
Abu Dhabi Harlequins v Jebel Ali Dragons, Friday, March 29, 5pm at The Sevens, Dubai
Padmaavat
Director: Sanjay Leela Bhansali
Starring: Ranveer Singh, Deepika Padukone, Shahid Kapoor, Jim Sarbh
3.5/5
Match info
Champions League quarter-final, first leg
Liverpool v Porto, Tuesday, 11pm (UAE)
Matches can be watched on BeIN Sports
New UK refugee system
- A new “core protection” for refugees moving from permanent to a more basic, temporary protection
- Shortened leave to remain - refugees will receive 30 months instead of five years
- A longer path to settlement with no indefinite settled status until a refugee has spent 20 years in Britain
- To encourage refugees to integrate the government will encourage them to out of the core protection route wherever possible.
- Under core protection there will be no automatic right to family reunion
- Refugees will have a reduced right to public funds
Essentials
The flights
Emirates, Etihad and Malaysia Airlines all fly direct from the UAE to Kuala Lumpur and on to Penang from about Dh2,300 return, including taxes.
Where to stay
In Kuala Lumpur, Element is a recently opened, futuristic hotel high up in a Norman Foster-designed skyscraper. Rooms cost from Dh400 per night, including taxes. Hotel Stripes, also in KL, is a great value design hotel, with an infinity rooftop pool. Rooms cost from Dh310, including taxes.
In Penang, Ren i Tang is a boutique b&b in what was once an ancient Chinese Medicine Hall in the centre of Little India. Rooms cost from Dh220, including taxes.
23 Love Lane in Penang is a luxury boutique heritage hotel in a converted mansion, with private tropical gardens. Rooms cost from Dh400, including taxes.
In Langkawi, Temple Tree is a unique architectural villa hotel consisting of antique houses from all across Malaysia. Rooms cost from Dh350, including taxes.
While you're here
Hend Al Otaiba: A year ago, Covid-19 forced us apart – now, vaccines can bring us back together
National Editorial: Iata travel pass – 'digital passports' will get the world moving again
Lucy Sherriff: Covid vaccine passports: safeguard or ethical nightmare?
Name: Colm McLoughlin
Country: Galway, Ireland
Job: Executive vice chairman and chief executive of Dubai Duty Free
Favourite golf course: Dubai Creek Golf and Yacht Club
Favourite part of Dubai: Palm Jumeirah
On Women's Day
Dr Nawal Al-Hosany: Why more women should be on the frontlines of climate action
Shelina Janmohamed: Why shouldn't a spouse be compensated fairly for housework?
Samar Elmnhrawy: How companies in the Middle East can catch up on gender equality
Justin Thomas: Challenge the notion that 'men are from Mars, women are from Venus'
On Women's Day
Dr Nawal Al-Hosany: Why more women should be on the frontlines of climate action
Shelina Janmohamed: Why shouldn't a spouse be compensated fairly for housework?
Justin Thomas: Challenge the notion that 'men are from Mars, women are from Venus'
The National Editorial: Is there much to celebrate on International Women's Day 2021?
Business Insights
- As per the document, there are six filing options, including choosing to report on a realisation basis and transitional rules for pre-tax period gains or losses.
- SMEs with revenue below Dh3 million per annum can opt for transitional relief until 2026, treating them as having no taxable income.
- Larger entities have specific provisions for asset and liability movements, business restructuring, and handling foreign permanent establishments.
