Participation and Foreign PE Exemptions

Document overview

Current Participation Exemption and foreign-PE exemption rules covering ownership interests, aggregation, the 9% subject-to-tax test, asset test, liquidation losses and recapture.

Applies to periods from 2025.
Includes a 9% subject-to-tax test.
Earlier periods require a separate historical version.

Scope and exclusions

Applies to

Applies to tax periods beginning on or after 1 January 2025 where the Participation Exemption or foreign-PE election is used.

Limitations and exclusions

MD 116/2023 remains the historical version for earlier periods; the exemption does not apply unless ownership, holding-period, subject-to-tax and other conditions are met.

Document text

An independent four-language editorial overview is published; the full instrument is not yet reproduced on-site.

This is an independent editorial overview, not the official text or a complete translation. Application requires checking the Arabic original, current version and transitional provisions.

An independent four-language editorial overview is published; the full instrument is not yet reproduced on-site.. This is an independent editorial overview, not the official text or a complete translation. Application requires checking the Arabic original, current version and transitional provisions.

Publication status

Source and translation status

The official Arabic text controls; the English version on the official portal is for reference. This page contains an independent SGC editorial overview.

Legal review

Number, date, scope, principal exclusions, effective status and official URL were checked; the overview is not advice on a specific matter. · September 13, 2026

Republication status

Only instrument metadata, an official deep link and an original editorial explanation are used. The FTA/MoF PDF, layout and compilation are not copied; full-text reproduction requires a separate source and rights review.

Change history

10 December 2024 — issued; applies to periods from 1 January 2025.
Reviewed 13 September 2026

Official primary source

Ministerial Decision No. 302 of 2024

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