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Federal Decree-Law No. 28 of 2025
Federal Decree-Law No. 28 of 2025 Amending Certain Provisions of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses
Machine translation of the Arabic original (no official English text found)
Preamble and recitals
Federal Decree-Law No. (28) of 2025 Amending Certain Provisions of Federal Decree-Law No. (47) of 2022 on the Taxation of Corporations and Businesses
We, Mohamed bin Zayed Al Nahyan, President of the United Arab Emirates,
-Having reviewed the Constitution,
-Federal Law No. (1) of 1972 on the Competencies of the Ministries and the Powers of the Ministers, and its amendments,
-Federal Decree-Law No. (47) of 2022 on the Taxation of Corporations and Businesses, and its amendments,
-Pursuant to what was presented by the Minister of Finance and the approval of the Cabinet,
Have issued the following Decree-Law:
#Article 1
The text of Article (44) of the aforementioned Federal Decree-Law No. (47) of 2022 shall be replaced by the following text:
New Article (44) – Calculation and Payment of Corporate Tax
Corporate Tax due under this Decree-Law shall be paid in the following order:
1.By using the Withholding Tax Credit attributable to the Taxable Person and determined under Article (46) of this Decree-Law.
2.Where a remaining amount of Corporate Tax due exists after applying Clause (1) of this Article, the Foreign Tax Credit available to the Taxable Person and determined under Article (47) of this Decree-Law shall be used.
3.Where a remaining amount of Corporate Tax due exists after applying Clause (2) of this Article, any credits or other forms of incentives or facilities determined by a decision issued by the Cabinet at the suggestion of the Minister shall be used.
4.Where a remaining amount of Corporate Tax payable exists after applying Clause (3) of this Article, it shall be paid in accordance with Article (48) of this Decree-Law.
#Article 2
A new article numbered (49 bis) shall be added to the aforementioned Federal Decree-Law No. (47) of 2022, the text of which is as follows:
New Article (49 bis) – Claiming the Unused Tax Credit Balance
1.A Taxable Person may claim the unused amount of the tax credits that may arise from the incentives or facilities prescribed under Paragraph (g) of Clause (2) of Article (20) and Clause (3) of Article (44) of this Decree-Law, in the cases and in accordance with the periods, controls and procedures issued by a decision of the Cabinet at the suggestion of the Minister.
2.The Authority may withhold amounts from the revenues of Corporate Tax and Top-up Tax for the purposes of settling the amounts claimed under Clause (1) of this Article, based on a decision of the Board of Directors of the Authority.
#Article 3
This Decree-Law shall be published in the Official Gazette and shall come into effect on the day following the date of its publication.
Mohamed bin Zayed Al Nahyan
President of the United Arab Emirates
Issued by us at the Presidential Palace – Abu Dhabi
Date: 9 Rabi' al-Akhir 1447 AH
Corresponding to: 1 October 2025 AD
Source: machine translation prepared for this database from the Arabic original.