Tax

CRS classification begins with the entity, not the account: you first decide whether a person is a Financial Institution or a Non-Financial Entity, and only then which of its accounts are reportable. The Common Reporting Standard is the OECD’s standard for the automatic exchange of financial account information, brought into UAE law by Cabinet Resolution No. 93 of 2021 and Ministerial Resolution No. 134 of 2021. An error at the first step invalidates everything that follows: a wrong entity status produces either unfiled reports or reports on accounts that never had to be reported at all.

The Domestic Minimum Top-up Tax (DMTT) is a UAE tax topping up the effective tax rate to 15%, introduced by Cabinet Decision No. 142 of 2024 and applicable for financial years beginning on or after 1 January 2025. It applies only to multinational groups with consolidated annual revenue of €750 million or more in at least two of the preceding four financial years. This implements the OECD/G20 Pillar Two global standard (GloBE Model Rules). For the vast majority of small and medium-sized businesses, this tax does not apply — the €750m threshold filters out everything except the largest-scale groups.

Three things in Hong Kong employment law moved at once in 2026. The continuous contract threshold fell from 18 hours a week to 17, with an alternative of 68 hours across four weeks. Offsetting of an employer’s mandatory MPF contributions against severance and long service payments has been abolished for service after 1 May 2025. And the statutory minimum wage has stood at HKD 43.1 an hour since 1 May 2026 — the first rate produced by a formula rather than settled by negotiation.

A Family Foundation in the UAE is not a distinct legal entity type — it is a tax status. Article 17 of Federal Decree-Law No. 47 of 2022 (the Corporate Tax Law) allows a foundation, trust, or similar entity to obtain Unincorporated Partnership status — fiscal transparency under which income is taxed in the hands of the beneficiaries rather than at the level of the structure itself. Trusts without separate legal personality (such as DIFC/ADGM trusts) are automatically transparent. Foundations with separate legal personality (DIFC Foundation, ADGM Foundation, RAK ICC Foundation) must apply to the Federal Tax Authority (FTA) and obtain approval. For individual beneficiaries, personal investment and real estate income is generally outside Corporate Tax regardless of the foundation’s own transparency status.

GPSSA (General Pension and Social Security Authority) is the federal pension fund for UAE nationals working in the government and private sectors in every emirate except Abu Dhabi (which has its own Abu Dhabi Pension Fund). Important: this system covers UAE nationals only — foreign employees do not receive a pension, they receive an end-of-service gratuity instead. Since 31 October 2023, two regimes apply in parallel: the old regime (Federal Law No. 7 of 1999, 20% contributions) for those registered with GPSSA before that date, and the new regime (Federal Decree-Law No. 57 of 2023, 26% contributions) for anyone entering the UAE workforce for the first time on or after that date.

An employer in Hong Kong must enrol every employee aged 18 to 64 in a Mandatory Provident Fund scheme within the first 60 days of employment and remit monthly mandatory contributions of 5 per cent of relevant income from its own funds, plus 5 per cent deducted from the employee. The duty covers full-time and part-time employees alike. The regulator is the Mandatory Provident Fund Schemes Authority (MPFA).

Three separate regimes drive the effective profits tax rate of a Hong Kong company that earns from intellectual property and from passive income. The patent box gives 5% on the concessionary portion of IP income. The two-tiered profits tax rates give 8.25% on the first HKD 2,000,000 of assessable profits and 16.5% above. FSIE is not a relief at all: it deems specified foreign-sourced dividends, interest, IP income and disposal gains received in Hong Kong by a member of an MNE group to be Hong Kong sourced unless an exception is met.

The R&D Tax Credit is a non-refundable UAE tax credit on qualifying research and development expenditure, introduced by Cabinet Decision No. 215 of 2025 and Ministerial Decision No. 24 of 2026, applicable for tax periods beginning on or after 1 January 2026. The credit rate is tiered: 15%, 35%, and 50%, depending on both the level of R&D expenditure and the average number of staff dedicated to R&D. The maximum credit is AED 2 million per tax period (50% of the maximum qualifying expenditure of AED 5 million). The credit is applied against Corporate Tax liability and, where applicable, Top-up Tax (DMTT).

Salaries tax in Hong Kong is charged not on residents but on income “arising in or derived from Hong Kong” from an office, an employment of profit or a pension — residence and nationality are irrelevant. The controlling question is always where the source of employment is located, not where the services were physically performed. The answer determines whether the whole income, part of it, or none of it is taxable, and whether the 60-day rule is available at all.

Small Business Relief (SBR) is a transitional measure under the UAE corporate tax framework. Any UAE-resident taxable person with revenue at or below AED 3 million may elect SBR and be treated as having zero taxable income for that tax period — effectively 0% corporate tax. SBR is available only for tax periods ending on or before 31 December 2026. The UAE Ministry of Finance has not announced any extension.

From 1 January 2026 UAE excise tax on sweetened drinks is charged as an amount per litre rather than a percentage of price, and that amount turns on the sugar content per 100 millilitres. The former flat 50 per cent of the excise price is gone. The new regime sits in Cabinet Decision No. 197 of 2025, issued on 27 November 2025.

Kazakhstan's currency regime runs on three separate tracks. A contract registration number is assigned to an export or import currency contract above USD 50,000 — the track that enforces repatriation of proceeds. Registration of capital movement contracts applies above USD 500,000. Notification of foreign bank accounts is mandatory for resident legal entities before any transaction on the account. The statutory basis is Law of the Republic of Kazakhstan No. 167-VI of 2 July 2018 "On Currency Regulation and Currency Control".

A UAE VAT-registered business can claim a refund of excess input tax through the FTA EmaraTax portal using Form VAT311, after submitting the relevant VAT201 return. The FTA reviews the application within 20 working days; approved refunds are paid within 5 working days. The critical 2026 change: under Federal Decree-Law No. 16 of 2025, excess input VAT can no longer be carried forward indefinitely. The maximum carry-forward period is now 5 years. Transitional deadline: credits from 2018–2020 must be claimed by 31 December 2026 or they lapse permanently.

Hong Kong operates three separate capital-deduction mechanisms under profits tax: the enhanced deduction for research and development under section 16B and Schedule 45 (300% on the first HK$2,000,000 and 200% above it), the deduction for capital expenditure on acquiring intellectual property rights under sections 16E and 16EA (100% in one year for patent rights and know-how, five equal instalments over five years for six named rights), and the deduction for environmental facilities under section 16I (100% in the year the expenditure is incurred). These are three distinct regimes with different conditions, different prohibitions and different clawback rules on disposal.

Stamp duty on the transfer of Hong Kong stock is charged at an aggregate of 0.2% — 0.1% on each of the two contract notes — plus a fixed HKD 5 on the instrument of transfer. The charge is computed on the consideration or the value of the stock, whichever is higher. The governing statute is the Stamp Duty Ordinance (Cap. 117), Head 2 of the First Schedule, administered by the Stamp Office of the Inland Revenue Department.

Hong Kong has introduced the 15% global minimum tax for multinational groups with consolidated revenue of EUR 750 million or more — through an income inclusion rule (IIR) and its own domestic top-up tax, the Hong Kong minimum top-up tax (HKMTT). Both apply to fiscal years beginning on or after 1 January 2025. The obligation bites not at the point of payment but at the point of administration: the notification is due six months after the end of the fiscal year and the return fifteen months after it, and both are filed exclusively online through the Inland Revenue Department’s Pillar Two Portal.

Most entrepreneurs thinking about "two jurisdictions" imagine two offshore entities for tax reduction. The Hong Kong + UAE dual structure operates on a fundamentally different logic. These are two complementary jurisdictions with different geographic reach, different legal systems, and different banking ecosystems — which together deliver more than either achieves alone.

A Hong Kong profits tax return is not a self-initiated annual filing — it is a response to an individual notice from the tax authority. The obligation arises the moment the Inland Revenue Department (IRD) issues a notice under section 51(1) of the Inland Revenue Ordinance (Cap. 112). BIR51 serves corporations, BIR52 serves persons other than corporations, and BIR54 is used in respect of non-resident persons. The bulk issue of 2025/26 returns took place on 1 and 2 April 2026; the default filing period is one month from the date of issue for BIR51 and BIR52, and two months for BIR54.

Kazakhstan no longer grants any dividend relief based on how long a participation has been held. The rule that exempted dividends where the shares or participation interest had been held for more than three years applied until 31 December 2022, survived for three more years in reduced form as a 10% rate, and disappeared altogether on 1 January 2026 with the repeal of the old Tax Code. The statute now looks at the size of the holding rather than its duration: a participant holding at least 25% of the capital of a Kazakh LLP pays 5% on dividends up to 230,000 times the monthly calculation index per calendar year and 15% above that ceiling. Every other non-resident pays 15%, and a recipient registered in a listed preferential-tax jurisdiction pays 20% regardless of holding size or duration.

A Hong Kong employer does not withhold income tax from an employee's pay. Its tax duty is a reporting duty: file the annual Employer's Return (Form BIR56A together with Forms IR56B) and notify the Inland Revenue Department during the year of every hire, cessation and departure using Forms IR56E, IR56F and IR56G. Running in parallel is the labour perimeter: the Employment Ordinance (Cap. 57), the Minimum Wage Ordinance (Cap. 608), the Mandatory Provident Fund Schemes Ordinance (Cap. 485) and the Employees' Compensation Ordinance (Cap. 282). The two perimeters are procedurally unconnected, but a breach of either is a criminal offence rather than an administrative one.

The 2026 payroll burden in Kazakhstan consists of three deductions from the employee's income — individual income tax (IIT), the mandatory pension contribution (OPV) and the medical insurance contribution (VOSMS) — and four charges borne by the employer: the employer pension contribution (OPVR) at 3.5%, social contributions at 5%, employer medical insurance deductions at 3% and social tax at 6%. Two statutory indicators run through every calculation: the monthly minimum wage (MZP) and the monthly calculation index (MCI).

Importing goods into Kazakhstan from a country outside the EAEU means the customs procedure of release for internal consumption, under which import duty, import VAT, excise and the customs fee are all paid before the goods are released — not after they are sold. The duty rate comes from the EAEU Common Customs Tariff as it stands on the day the declaration is registered, and import VAT is charged at 16% on the customs value increased by duty and excise. The declaration fee is a flat 6 MCI — KZT 25,950 in 2026 — whatever the consignment is worth.

Bringing goods into the UAE runs through two independent circuits: customs and tax. The customs circuit is run by the emirate — importer registration, the declaration, 5% duty on the CIF value. The tax circuit is run federally — 5% VAT on a base that includes the duty, with the option of not paying it at the border if the tax registration number is linked to the customs registration number. The two circuits meet at exactly one point, and that point is the one most often left unconfigured.

A completely rebuilt investment preference regime has applied in Kazakhstan since 1 January 2026. Law of the Republic of Kazakhstan No. 215-VIII of 18 July 2025 excluded articles 286, 287, 288, 289, 290, 295-1 and 295-3 from the Entrepreneurial Code and inserted a new block, articles 283-1 to 283-5, in their place. Investment preferences are now granted under one of three instruments only — an investment agreement, an investment obligations agreement or a simplified investment contract — and under one of them at a time. The tax side moved into chapter 81 of the new Tax Code No. 214-VIII, which took effect on the same day.

A Kazakhstan + UAE dual structure pairs an operating company in Kazakhstan — handling the local market, staff and counterparties — with a UAE company holding the international perimeter: intellectual property, export contracts, shareholdings or financing. It rests on three pillars: a double tax convention in force, the absence of the UAE from Kazakhstan’s list of states with preferential taxation, and the gap between 20% corporate income tax in Kazakhstan and 9% corporate tax in the UAE.

Since 1 January 2026 tax control in Kazakhstan has been governed by a new Tax Code — Code of the Republic of Kazakhstan No. 214-VIII of 18 July 2025, which replaced Code No. 120-VI of 25 December 2017. More than the article numbering changed: desk control no longer issues a “notice to remedy breaches” but a notice of discrepancies; tax control has been narrowed to tax audits alone; and the limitation period has split into three and five years by taxpayer category. The appeal architecture remains double and asymmetric: one notification may go either to the Ministry of Finance or straight to court, while every other notification passes through the general pre-court procedure of the Administrative Procedure Code.

Controlled foreign company rules are addressed not to the foreign company but to its Kazakhstan owner. The mechanism is that, where defined conditions are met, the profit of a foreign company is included in the taxable income of a Kazakhstan resident and taxed in Kazakhstan — even where no dividend has been distributed and the money has stayed abroad. The regime sits in Chapter 33 of the Tax Code of the Republic of Kazakhstan (Law No. 214-VIII of 18 July 2025), in force from 1 January 2026.

Corporate tax (CT) is a federal tax on profits of legal entities and natural persons from business activities in the UAE, introduced by Federal Decree-Law No. 47 of 2022. In force from 1 June 2023. For the first time in UAE history, a direct profits tax applies to the vast majority of commercial entities.

A natural person in the UAE pays corporate tax only where that person conducts a business and the gross turnover from that business exceeds AED 1,000,000 in a Gregorian calendar year. The threshold sits in Article 2(1) of Cabinet Decision No. 49 of 2023. Below it, no registration is required at all. Above it, the natural person becomes a Taxable Person and must register, keep records, file a return and pay tax at 9% on taxable income above AED 375,000.

Kazakhstan withholding tax is deducted by the Kazakhstan payer from a foreign company's income sourced in the Republic of Kazakhstan, with no deductions allowed. The headline rate is 20 per cent; dividends, royalties and interest carry 15 per cent; interest on loans and debt securities carries 10 per cent; international transport services carry 5 per cent. The framework from 1 January 2026 is Division 15 of the new Tax Code (Code of the Republic of Kazakhstan No. 214-VIII of 18 July 2025), articles 679 to 687 and chapter 75.

A Tax Group in the UAE is a regime under which a parent company and its subsidiaries are treated as a single taxable person for corporate tax purposes: one consolidated return is filed and the profits and losses of the members are offset against one another. The regime sits in Articles 40 to 42 of Federal Decree-Law No. 47 of 2022 and is fleshed out by Ministerial Decision No. 301 of 2024.

A family investment vehicle in Hong Kong is charged to profits tax at 0% where it is managed by an eligible single family office and the aggregate net asset value under that office’s management is at least HK$240,000,000. The legal basis is Schedule 16E to the Inland Revenue Ordinance (Cap. 112), inserted by Ord. No. 8 of 2023 and applying from the year of assessment commencing 1 April 2022. This is not an automatic exemption. It requires an irrevocable written election, annual satisfaction of quantitative thresholds, and at least two qualified full-time employees in Hong Kong.

Since 1 January 2026, Kazakhstan has operated under a new Tax Code, replacing the code of 25 December 2017: VAT has risen from 12% to 16%, a progressive PIT rate (10%/15%) has been introduced, and AIFC companies retain a 0% rate on financial services until 2066.

A UAE residence visa is an immigration status. It authorises living and working in the UAE. It is issued by ICP or GDRFA.

UAE tax residency is a tax status. It confirms that an individual is a tax resident of the UAE. It is evidenced by a Tax Residency Certificate (TRC) issued by the Federal Tax Authority (FTA).

UAE tax residency and immigration status are two separate things. A residence visa (including the Golden Visa) protects immigration status but does not make you a UAE tax resident. Tax residency is determined by physical presence and other factors under Cabinet Decision No. 85 of 2022. During extended absence, two independent risks arise: loss of UAE tax residency and potential tax residency in the country of stay.

An individual becomes a Kazakhstan tax resident on either of two independent grounds: permanent presence in the country of at least 183 calendar days in any consecutive 12-month period, or a centre of vital interests located in Kazakhstan. A resident pays Kazakhstan personal income tax on income from sources both inside and outside Kazakhstan. Declaration is a separate obligation: foreign accounts, foreign assets and digital assets go into forms 250.00 and 270.00 whether or not they produced any income.

Income earned by an individual from letting or selling UAE real estate is generally outside the scope of UAE Corporate Tax altogether — regardless of amount. The same property held by a UAE company produces Corporate Tax at 9% on profit above AED 375,000. This is not a computational nuance but a difference in the scope of taxation itself, and it turns on a single test: whether a licence is held or required.

Hong Kong has no separate crypto tax and no digital-asset provisions in the Inland Revenue Ordinance. Profits from digital assets fall within profits tax under the ordinary machinery of section 14 of Cap. 112 where they are trading profits with a Hong Kong source; capital gains are not taxed at all. The only Inland Revenue Department guidance on the substance is DIPN 39 (Revised) of March 2020, which has not been updated since. The practical consequence is that everything turns on the line between trading stock and a capital asset, and that line is drawn by the intention at acquisition and by nine questions set out by the Court of Final Appeal.

A new Tax Code took effect in Kazakhstan on 1 January 2026 — Code of the Republic of Kazakhstan No. 214-VIII of 18 July 2025. The standard VAT rate rose from 12% to 16%, and the turnover threshold for compulsory VAT registration was halved from 20,000 MCI to 10,000 MCI. With the monthly calculation index (MCI) set at KZT 4,325 for 2026, that threshold is KZT 43,250,000. The filing window for the registration application has been cut to five working days from the date the threshold is exceeded.

On 1 January 2018, the UAE introduced Value Added Tax (VAT) — a consumption-based indirect tax ultimately borne by end consumers, with businesses acting as its collectors on behalf of the government. The introduction of VAT was part of the UAE's economic diversification strategy under the GCC Unified VAT Agreement.

VAT on goods brought into Kazakhstan from an EAEU member state is paid by the importer, not the supplier, and it is paid whether or not the importer is registered for VAT. The standard rate from 1 January 2026 is 16%. The only tax form the importer files is the application on the importation of goods and the payment of indirect taxes — form 328.00. Both the form and the payment fall due on the same date: no later than the 20th of the month following the month in which the goods were taken onto the books.

The most underestimated tax and technological topic in the UAE as of April 2026 is not a new tax rate, but mandatory electronic invoicing.

The duty to keep accounts and the duty to be audited come from different Kazakh statutes and turn on different tests. Accounting and reporting sit in Law № 234-III of 28 February 2007 “On accounting and financial reporting”; audit sits in Law № 304-I of 20 November 1998 “On auditing activity”. A company can be obliged to file with the depository and still not be subject to mandatory audit — and the reverse is equally possible.

Mandatory audit in the UAE typically follows from three independent sources of obligation: Federal Decree-Law No. 32 of 2021 (Commercial Companies Law) for mainland companies, PJSCs, and PrJSCs; the internal rules of the specific free zone for licence renewal; and Ministerial Decision No. 84 of 2025 for Corporate Tax purposes. An audit is mandatory for Qualifying Free Zone Persons (regardless of revenue), for any taxable person with revenue exceeding AED 50 million in the tax period, for all Tax Groups, and for most companies in major free zones (DMCC, JAFZA, DIFC, ADGM, and others) — independently of the tax rules, as a condition of licence renewal.

A foreign company falls within UAE corporate tax on three independent grounds, set out in Article 11(4) of Federal Decree-Law No. 47 of 2022: having a permanent establishment in the UAE, deriving State Sourced Income, or having a nexus in the UAE as determined by Cabinet decision. None of these requires incorporating in the UAE, and none depends on the company's own choice — they arise from facts.

A permanent establishment turns a foreign company from a recipient of income taxed at source into a taxpayer in its own right in Kazakhstan: it computes its own taxable income, files its own return and pays its own corporate income tax. Under Article 226 of the new Tax Code — Code of the Republic of Kazakhstan No. 214-VIII of 18 July 2025, in force from 1 January 2026 — a permanent establishment arises in four cases: a permanent place of activity, the supply of services through hired personnel, activity through a dependent agent, and joint activity.

The agreed-upon procedures (AUP) report under FTA Decision No. 6 of 2026 is a document that a Qualifying Free Zone Person (QFZP) engaged in the Qualifying Activity of distributing goods or materials in or from a Designated Zone must obtain from an independent external auditor licensed in the UAE. The report must be submitted to the Federal Tax Authority (FTA) no later than 30 days after the deadline for filing the company’s Corporate Tax return.

A Certificate of Resident Status (CoR) is the document the Hong Kong competent authority issues to a Hong Kong resident who needs proof of residence in order to claim benefits under a Comprehensive Double Taxation Agreement or Arrangement (CDTA). Since 12 June 2023 the Inland Revenue Department has decided applications purely on the plain definition of "resident of Hong Kong" in the relevant agreement, without separately assessing economic substance. The certificate is free, the target processing time is 21 working days, and a single application can cover up to three calendar years.

A Tax Residency Certificate (TRC) — also referred to in the UAE as a Tax Domicile Certificate — is an official document issued by the Federal Tax Authority (FTA) that legally confirms an individual or legal entity is a tax resident of the United Arab Emirates for a specific 12-month period.

Kazakhstan's special tax regimes were cut to three with effect from 1 January 2026: the regime for the self-employed, the regime based on the simplified declaration, and the regime for peasant and farm enterprises. The framework is Division 16 of the new Tax Code (Code of the Republic of Kazakhstan No. 214-VIII of 18 July 2025), articles 715 to 733. The patent regime, the special mobile application regime and the retail tax regime no longer exist.

An objection to a Hong Kong tax assessment must reach the Commissioner of Inland Revenue within one month after the date of the notice of assessment, and an appeal against the Commissioner’s determination must reach the Clerk to the Board of Review within one month after that determination is transmitted to the taxpayer. Both periods are set by the Inland Revenue Ordinance (Cap. 112) and both are hard deadlines, extendable only on a narrow set of grounds. Lodging an objection does not suspend the obligation to pay: Hong Kong runs a pay-first, argue-later system. Payment can be held over, but holding over is a discretion of the Commissioner, not an entitlement of the taxpayer.

Hong Kong charges Profits Tax only on profits arising in or derived from Hong Kong; profits from foreign sources are not taxed, but only if the company can document that the activity generating the profit genuinely took place outside Hong Kong.

Transfer pricing in Hong Kong is governed by Part 8AA of the Inland Revenue Ordinance (Cap. 112), introduced by the Inland Revenue (Amendment) (No. 6) Ordinance 2018. The regime rests on two substantive rules — the arm's length principle for transactions between associated persons (section 50AAF) and the attribution of profits to a permanent establishment (section 50AAK) — supported by three tiers of documentation: master file, local file and country-by-country report. Departmental Interpretation and Practice Notes Nos. 58, 59 and 60 set out how the Inland Revenue Department applies them.

Transfer pricing in Kazakhstan is governed by a standalone statute — Law of the Republic of Kazakhstan No. 67-IV of 5 July 2008 “On Transfer Pricing” — and not by the Tax Code. Three-tier reporting consists of the local file (form 013 МО), the master file (form 014 ОО) and the country-by-country report (form 012 МО), alongside the notification of participation in a multinational group (form 011 ЗУ). From 1 January 2026 the Law contains a new Article 10-2 on the accurate delineation of the controlled transaction and functional analysis — the most substantive change to the regime in years.

Transfer pricing in the UAE is governed by Chapter Ten of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses. The arm's length principle in Article 34 applies to every transaction and arrangement with a Related Party, regardless of the size of the business or its turnover. The thresholds set by Ministerial Decision No. 97 of 2023 determine only the obligation to maintain a Local File and Master File — they neither displace the principle itself nor remove the duty to substantiate pricing on request from the Federal Tax Authority.

Detailed analysis of the latest changes in the tax legislation of the UAE — amendments to the Executive Regulations on Tax Procedures effective from 1 April 2026, VAT, Corporate Tax, Domestic Minimum Top-up Tax, R&D Tax Credit, eInvoicing, Excise Tax, and practical consequences for business.

A dispute with the UAE Federal Tax Authority runs through four consecutive stages set by Federal Decree-Law No. 28 of 2022 on Tax Procedures: an application for Tax Assessment Review under Article 28, an application for Reconsideration under Article 29, an objection to the Tax Disputes Resolution Committee under Articles 30 to 33, and an appeal to the competent court under Article 36. Skipping a stage closes the next one: a court will not admit a tax claim where no objection was first filed with the Committee.

From 1 January 2026 the issuance of invoices in Kazakhstan is governed by the new Tax Code No. 214-VIII and by Order No. 629 of the Minister of Finance of 28 October 2025. The previous e-invoice rules — Order No. 370 of 22 April 2019 — have been repealed in full. The headline change: where a tax risk is identified, an electronic invoice must additionally be certified with the biometric data of the individual issuing it, and without passing biometric identification the invoice cannot be issued at all.