Business
Structuring Group Entities Across Jurisdictions — The Key to Global Efficiency
9%
UAE CT rate — competitive globally
140+
UAE double tax treaties in force
15%
OECD Pillar Two global minimum rate
As UAE businesses expand regionally and globally, structuring group entities effectively is now a strategic business decision with material financial consequences. The introduction of Corporate Tax, transfer pricing rules and the UAE’s evolving treaty network have all raised the stakes.
Common Cross-Border Structuring Models
The Participation Exemption
To qualify for the Participation Exemption:
✓Hold at least 5% of subsidiary shares
✓Continuous holding for at least 12 months
✓Subsidiary is not a UAE Exempt Person
✓Not resident in a 0% jurisdiction without genuine business
Client Case Illustration
A GCC-headquartered group restructured its regional holding following UAE CT introduction. Univia assessed QFZP conditions, reviewed intercompany flows against transfer pricing requirements and recommended a revised structure that maintained the participation exemption on dividends from four operating subsidiaries.
Contact Univia: info@univiaglobal.com | +971 50 223 5283
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