This guide explains which Entities are excluded from UAE Top-up Tax and which qualify as Investment Entities under the QDMTT Legislation. It covers the primary Excluded Entities - International Organisations, Non-profit Organisations, Pension Funds and Pension Services Entities, Investment Funds and Real Estate Investment Vehicles that are Ultimate Parent Entities - and the ownership and activities tests for secondary Excluded Entities held through them. It addresses Permanent Establishments of Excluded Entities, the election not to be an Excluded Entity, primary and secondary Investment Entities including Insurance Investment Entities, and the practical filing and Top-up Tax consequences of each classification, with worked examples throughout.
Excluded Entities and Investment Entities
Top-up Tax Guide | TTGEIE1
August 2026
Contents
1. Glossary
2. Introduction
2.1. Overview
2.2. Purpose of this guide
2.3. Who should read this guide?
2.4. How to use this guide
2.5. Legislative references
2.6. Status of this guide
3. Entities not subject to Top-up Tax
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