GCC Tax Flash News – April 2025

United Arab Emirates (UAE)

• The Ministry of Finance (MoF) and the Federal Tax Authority (FTA) announced penalty waiver scheme for late CT registration. Businesses can take benefit of this scheme by filing their first CT return within 7 months from end of the financial year
• Cabinet Decision No. 34 of 2025 issued to enhance the CT framework, defining the exemption criteria for Qualifying Investment Funds and Qualifying Limited Partnerships under the CT law
• The MoF issued Cabinet Decision no. 35 of 2025 on Determining Non-Resident Person’s nexus in the UAE for CT purposes
• Cabinet Decision no. 84 of 2025 issued on conditions for getting the Financial Statement audited for UAE CT purposes
• The FTA published CT Guide (CTGIDL1) on Interest Deduction Limitation Rules

• To improve service and simplify registration requirements, the FTA has reduced the business activity selection fields from 4 to 1. As a part of compliance requirements, all registered taxpayers must mandatorily update their primary activity on the Emara tax portal
• The FTA released data on CT, VAT and Excise Tax registrations in the UAE. As per the data, total 519,789 companies are registered for CT, 469,976 for VAT and 1,754 for Excise Tax

• The FTA issued new Public Clarification (VATP041) on SWIFT message
• The FTA issued new Public Clarification (VATP043 replacing VATP032) on application of the reverse charge mechanism on precious metals and precious stones between registrants in the UAE
• The FTA issued VAT Public Clarification (VATP042) on value of supply and taxability of barter transactions

• As per the recommendation of the Advisory Committee, the UAE has imposed a provisional antidumping duty on imports of “white Mushrooms” originating in or exported from the Islamic Republic of Iran. The provisional duty shall be effective from 1 April 2025 for a period of four months

• The MoF has issued Ministerial Decision No. 88 of 2025, formally adopting the OECD Commentary and Administrative Guidance on the Global Anti-Base Erosion Model Rules (Pillar Two) for the application of Cabinet Decision No. 142 of 2024, concerning the imposition of Top-Up Tax on Multinational Enterprises

• The MoF has organised an important session on the feedback received on the public consultation document on E-invoicing programme and E-invoicing data dictionary related to E-Invoicing implementation (released in February 2025)

Kingdom of Saudi Arabia (KSA)

• The Zakat, Tax and Customs Authority (ZATCA) published the amended VAT Implementing Regulations in the Official Gazette on 18 April 2025

• ZATCA published an updated implementing regulations for the Real Estate Transaction Tax (RETT), following the new RETT Law (Royal Decree-Law no. M/84) which takes effect on 9 April 2025

• ZATCA published a detailed guidelines to support the businesses for filing of Zakat and Tax and withholding tax returns

• The Ministry of Commerce announced implementation of the new Law of Commercial Register and Law of Trade Names, along with their associated regulations, effective from 3 April 2025. Key changes include establishment of a unified commercial registry, encompassing all business activities across the Kingdom and also requiring the businesses with branch registrations either to convert their branches into separate legal entities or close them by April 2030
• The KSA introduces new UBO Rules, effective 3 April 2025, requiring most companies to disclose their UBOs to the Ministry of Commerce

• Saudi Councils of Ministers authorises to sign DTA with Bahrain, and approves DTA with Croatia and Kuwait

Kingdom of Bahrain

• Shura Council financial and economic affairs committee chairman confirmed that Bahrain is prepared to introduce new taxation measures to diversify the revenue which includes corporate income tax (domestic) and tax on carbon emissions