Corporate tax in the UAE, launched on June 1, 2023, is now having an impact on ever more existing entities whose new fiscal year is only beginning.
This is driving members of the business community to look anew at themselves.
A business is made up of more elements than many might realise. Besides core trading, there is the question of whether there are processes or components that are distinctive enough to consider them patents.
After all, businesses survive by inventing and innovating themselves into current relevance, such is the essence of competition.
The recent release of Cabinet Decision No 100, a five-page extension adding to the guidance on qualifying free zone persons, should particularly resonate with those self-aware enough to protect their intellectual property.
Effective national tax law encourages strategically targeted economic activities. The introduction of qualifying intellectual property carves out patents and software as elements that will attract zero per cent corporate tax.
Let us deal with patents first. Patents awarded anywhere under a competent authority are recognised.
More interesting is the recognition of equivalency. These are described as including “utility models, intellectual property assets that grant protection to plants and genetic material, (and) orphan drug designations”.
Proving there is no such thing as a free lunch, there are provisos. Marketing-related intellectual property, such as trademarks, do not qualify.
It is not unfair to think of patents as a very expensive path to protecting your work and what I am outlining above may be beyond the treasury of many.
Good news. The UAE government has already laid the groundwork for supporting a quasi-form of the same. The scope of the solution is clearly defined.
Called a utility certificate, this protects the innovation of technical ideas where the rules of nature underpin the solution. By this, they mean shape, structure or combination.
For avoidance of doubt, a patent is a greatly elevated version of the same. These are issued by the Development of Innovation in the Economy and Patents Department.
Called industrial design, the same department will also issue protection for rights to shape, pattern, colour or combination of these in a three dimensional form for aesthetic purposes.
How many of you in the production space know about these?
On to copyrighted software. Its inclusion appears linked to a 2020 ministerial decision that decreed its similarity to patent assets. The Federal Tax Authority is likely to release a document that drills further down into the details that would highlight particular divergences.
Until now we have only been looking at income. What about the qualifying costs? On this detail is light. However, it would appear that the OECD framework is being followed. Using that we can make some informed predictions.
All research and development costs incurred in the UAE, potentially including those from parties outside free zones and foreign based unconnected persons, might be allowable.
This total can have an additional 30 per cent of other costs added to come to a sum number. The principle is that costs are rarely incurred standalone and need supporting elements to ensure their effectiveness.
What is missing is any direction regarding acquisition costs of intellectual property.
The object here is to create what we can call the UAE patent box. It’s a well-developed framework used by governments globally to encourage the development and domiciling of commercial intellectual property in their respective domestic markets.
This demonstrates the UAE’s determination to compete internationally within the norms of other standard government approaches.
I leave you with this observation and a call for you to be ever more attentive. Corporate tax law is currently very fluid.
Decisions from the three relevant authorities, the Cabinet, Ministry of Finance and the Federal Tax Authority are being released at an accelerated rate.
Specifically, keep a watch on what has been previously released and has been subsequently changed. The following is an example.
Ministerial Decision No. 139, released in June 2023, has been repealed and superseded by Ministerial Decision No. 265, released in October 2023. This detail sits at the end of the latter document.
It would be very easy to miss this repealing clause and formulate your tax planning using out-of-date information.
David Daly is a partner at the Gulf Tax Accounting Group in the UAE
Your Guide to the Home
- Level 1 has a valet service if you choose not to park in the basement level. This level houses all the kitchenware, including covetable brand French Bull, along with a wide array of outdoor furnishings, lamps and lighting solutions, textiles like curtains, towels, cushions and bedding, and plenty of other home accessories.
- Level 2 features curated inspiration zones and solutions for bedrooms, living rooms and dining spaces. This is also where you’d go to customise your sofas and beds, and pick and choose from more than a dozen mattress options.
- Level 3 features The Home’s “man cave” set-up and a display of industrial and rustic furnishings. This level also has a mother’s room, a play area for children with staff to watch over the kids, furniture for nurseries and children’s rooms, and the store’s design studio.
The specS: 2018 Toyota Camry
Price: base / as tested: Dh91,000 / Dh114,000
Engine: 3.5-litre V6
Gearbox: Eight-speed automatic
Power: 298hp @ 6,600rpm
Torque: 356Nm @ 4,700rpm
Fuel economy, combined: 7.0L / 100km
Plan to boost public schools
A major shake-up of government-run schools was rolled out across the country in 2017. Known as the Emirati School Model, it placed more emphasis on maths and science while also adding practical skills to the curriculum.
It was accompanied by the promise of a Dh5 billion investment, over six years, to pay for state-of-the-art infrastructure improvements.
Aspects of the school model will be extended to international private schools, the education minister has previously suggested.
Recent developments have also included the introduction of moral education - which public and private schools both must teach - along with reform of the exams system and tougher teacher licensing requirements.
TWISTERS
Director: Lee Isaac Chung
Starring: Glen Powell, Daisy Edgar-Jones, Anthony Ramos
Rating: 2.5/5
Recipe
Garlicky shrimp in olive oil
Gambas Al Ajillo
Preparation time: 5 to 10 minutes
Cooking time: 5 minutes
Serves 4
Ingredients
180ml extra virgin olive oil; 4 to 5 large cloves of garlic, minced or pureed (or 3 to 4 garlic scapes, roughly chopped); 1 or 2 small hot red chillies, dried (or ¼ teaspoon dried red chilli flakes); 400g raw prawns, deveined, heads removed and tails left intact; a generous splash of sweet chilli vinegar; sea salt flakes for seasoning; a small handful of fresh flat-leaf parsley, roughly chopped
Method
▶ Heat the oil in a terracotta dish or frying pan. Once the oil is sizzling hot, add the garlic and chilli, stirring continuously for about 10 seconds until golden and aromatic.
▶ Add a splash of sweet chilli vinegar and as it vigorously simmers, releasing perfumed aromas, add the prawns and cook, stirring a few times.
▶ Once the prawns turn pink, after 1 or 2 minutes of cooking, remove from the heat and season with sea salt flakes.
▶ Once the prawns are cool enough to eat, scatter with parsley and serve with small forks or toothpicks as the perfect sharing starter. Finish off with crusty bread to soak up all that flavour-infused olive oil.
UK-EU trade at a glance
EU fishing vessels guaranteed access to UK waters for 12 years
Co-operation on security initiatives and procurement of defence products
Youth experience scheme to work, study or volunteer in UK and EU countries
Smoother border management with use of e-gates
Cutting red tape on import and export of food
Who's who in Yemen conflict
Houthis: Iran-backed rebels who occupy Sanaa and run unrecognised government
Yemeni government: Exiled government in Aden led by eight-member Presidential Leadership Council
Southern Transitional Council: Faction in Yemeni government that seeks autonomy for the south
Habrish 'rebels': Tribal-backed forces feuding with STC over control of oil in government territory
Benefits of first-time home buyers' scheme
- Priority access to new homes from participating developers
- Discounts on sales price of off-plan units
- Flexible payment plans from developers
- Mortgages with better interest rates, faster approval times and reduced fees
- DLD registration fee can be paid through banks or credit cards at zero interest rates
At Eternity’s Gate
Director: Julian Schnabel
Starring: Willem Dafoe, Oscar Isaacs, Mads Mikkelsen
Three stars
Film: Raid
Dir: Rajkumar Gupta
Starring: Ajay Devgn, Ileana D'cruz and Saurabh Shukla
Verdict: Three stars
Dust and sand storms compared
Sand storm
- Particle size: Larger, heavier sand grains
- Visibility: Often dramatic with thick "walls" of sand
- Duration: Short-lived, typically localised
- Travel distance: Limited
- Source: Open desert areas with strong winds
Dust storm
- Particle size: Much finer, lightweight particles
- Visibility: Hazy skies but less intense
- Duration: Can linger for days
- Travel distance: Long-range, up to thousands of kilometres
- Source: Can be carried from distant regions
RESULT
Liverpool 4 Southampton 0
Jota (2', 32')
Thiago (37')
Van Dijk (52')
Man of the match: Diogo Jota (Liverpool)
List of alleged parties
- May 15 2020: Boris Johnson is said to have attended a Downing Street pizza party
- 27 Nov 2020: PM gives speech at leaving do for his staff
- Dec 10 2020: Staff party held by then-education secretary Gavin Williamson
- Dec 13 2020: Mr Johnson and his then-fiancee Carrie Symonds throw a flat party
- Dec 14 2020: Shaun Bailey holds staff party at Conservative Party headquarters
- Dec 15 2020: PM takes part in a staff quiz
- Dec 18 2020: Downing Street Christmas party
Cryopreservation: A timeline
- Keyhole surgery under general anaesthetic
- Ovarian tissue surgically removed
- Tissue processed in a high-tech facility
- Tissue re-implanted at a time of the patient’s choosing
- Full hormone production regained within 4-6 months
Tips on buying property during a pandemic
Islay Robinson, group chief executive of mortgage broker Enness Global, offers his advice on buying property in today's market.
While many have been quick to call a market collapse, this simply isn’t what we’re seeing on the ground. Many pockets of the global property market, including London and the UAE, continue to be compelling locations to invest in real estate.
While an air of uncertainty remains, the outlook is far better than anyone could have predicted. However, it is still important to consider the wider threat posed by Covid-19 when buying bricks and mortar.
Anything with outside space, gardens and private entrances is a must and these property features will see your investment keep its value should the pandemic drag on. In contrast, flats and particularly high-rise developments are falling in popularity and investors should avoid them at all costs.
Attractive investment property can be hard to find amid strong demand and heightened buyer activity. When you do find one, be prepared to move hard and fast to secure it. If you have your finances in order, this shouldn’t be an issue.
Lenders continue to lend and rates remain at an all-time low, so utilise this. There is no point in tying up cash when you can keep this liquidity to maximise other opportunities.
Keep your head and, as always when investing, take the long-term view. External factors such as coronavirus or Brexit will present challenges in the short-term, but the long-term outlook remains strong.
Finally, keep an eye on your currency. Whenever currency fluctuations favour foreign buyers, you can bet that demand will increase, as they act to secure what is essentially a discounted property.
UAE currency: the story behind the money in your pockets
Mercer, the investment consulting arm of US services company Marsh & McLennan, expects its wealth division to at least double its assets under management (AUM) in the Middle East as wealth in the region continues to grow despite economic headwinds, a company official said.
Mercer Wealth, which globally has $160 billion in AUM, plans to boost its AUM in the region to $2-$3bn in the next 2-3 years from the present $1bn, said Yasir AbuShaban, a Dubai-based principal with Mercer Wealth.
“Within the next two to three years, we are looking at reaching $2 to $3 billion as a conservative estimate and we do see an opportunity to do so,” said Mr AbuShaban.
Mercer does not directly make investments, but allocates clients’ money they have discretion to, to professional asset managers. They also provide advice to clients.
“We have buying power. We can negotiate on their (client’s) behalf with asset managers to provide them lower fees than they otherwise would have to get on their own,” he added.
Mercer Wealth’s clients include sovereign wealth funds, family offices, and insurance companies among others.
From its office in Dubai, Mercer also looks after Africa, India and Turkey, where they also see opportunity for growth.
Wealth creation in Middle East and Africa (MEA) grew 8.5 per cent to $8.1 trillion last year from $7.5tn in 2015, higher than last year’s global average of 6 per cent and the second-highest growth in a region after Asia-Pacific which grew 9.9 per cent, according to consultancy Boston Consulting Group (BCG). In the region, where wealth grew just 1.9 per cent in 2015 compared with 2014, a pickup in oil prices has helped in wealth generation.
BCG is forecasting MEA wealth will rise to $12tn by 2021, growing at an annual average of 8 per cent.
Drivers of wealth generation in the region will be split evenly between new wealth creation and growth of performance of existing assets, according to BCG.
Another general trend in the region is clients’ looking for a comprehensive approach to investing, according to Mr AbuShaban.
“Institutional investors or some of the families are seeing a slowdown in the available capital they have to invest and in that sense they are looking at optimizing the way they manage their portfolios and making sure they are not investing haphazardly and different parts of their investment are working together,” said Mr AbuShaban.
Some clients also have a higher appetite for risk, given the low interest-rate environment that does not provide enough yield for some institutional investors. These clients are keen to invest in illiquid assets, such as private equity and infrastructure.
“What we have seen is a desire for higher returns in what has been a low-return environment specifically in various fixed income or bonds,” he said.
“In this environment, we have seen a de facto increase in the risk that clients are taking in things like illiquid investments, private equity investments, infrastructure and private debt, those kind of investments were higher illiquidity results in incrementally higher returns.”
The Abu Dhabi Investment Authority, one of the largest sovereign wealth funds, said in its 2016 report that has gradually increased its exposure in direct private equity and private credit transactions, mainly in Asian markets and especially in China and India. The authority’s private equity department focused on structured equities owing to “their defensive characteristics.”
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