In line with the Cabinet Decision No. 65 of 2020 on Fees for Services provided by the Federal Tax Authority issued in October 2020. The Federal Tax Authority (FTA), and in coordination with the Ministry of Finance (MOF) started receiving applications for the issuance of tax certificates via its website as of 14th November 2020.
There are two categories of tax certificates which will be issued to Legal and Natural Persons:
• Tax Residency Certificate: a certificate issued by the FTA upon request to enable applicants to benefit from Double Tax Avoidance Agreements (DTAA) on income signed by the UAE.
• Commercial Activities Certificate: a certificate issued by the FTA to enable applicants to refund VAT paid outside the UAE, whether or not DTAAs are applicable.
The new service provides advantages and ease for the issuance of certificates to those registered in the tax system, as all their data is available in the FTA database so they can apply for Tax Certificates through direct and quick digital procedures.
We would urge you to review our Tax Certificates Service User Guide on the Federal Tax Authority’s website through the following link:
https://tax.gov.ae/-/media/Files/EN/PDF/Guides/TRCFTAApplicant-User-ManualENG-v-0213006.pdf
https://tax.gov.ae/en/TRC

The following goods are excluded from the definition of Sweetened Drinks and are, therefore, not subject to the new Excise Tax model:
• Beverages that contain at least 75% milk of the ready-to-drink beverage content; 
• Beverages that contain milk alternatives made from plant sources of at least 75% of the ready-to-drink beverage content;
• Infant formula or follow-up milk formula or baby food;
• Beverages intended for special dietary needs; 
• Beverages and concentrates containing any added source of sugar or sweeteners that are prepared by individuals for personal consumption or for non-commercial purposes; 
• Beverages containing any added source of sugar or sweeteners that are prepared in restaurants and served in an open container to consumers for direct consumption.

The terms “Business” and “Business Activity” as defined in the Corporate Tax Law identify when the activities of certain persons give rise to a UAE CT liability by considering the person to be a taxable person.

“Business” means any economic activity, whether continuous or short term, conducted by any person. It is implied that a business is conducted with a profit motive, and that there is the existence of some system and organisation to the activity conducted. However, a business or business activity for UAE CT purposes does not lose its identity simply because it does not make a profit.

For the application of the Corporate Tax Law to companies and other juridical persons, all activities conducted and assets used or held will generally be considered activities conducted, and assets used or held, for the purposes of a “Business”.

Individuals can earn income from wages and salaries, investments or from practising a commercial, industrial or professional activity, either directly or as sole proprietor of a business. For natural persons, a Cabinet Decision will be issued in due course specifying further information on what would bring a natural person within the scope of UAE CT.

A commercial building is any building or part thereof that is not a residential building. Examples would be offices, warehouses, hotels, shops, etc.

All supplies of commercial properties are subject to VAT at 5%, and this includes all buildings or parts thereof that are not residential buildings.

An owner of a residential building is not able to recover VAT in respect of expenses related to the exempt supply of the residential building.

An owner of a commercial building is generally able to recover VAT in respect of expenses related to the supply of the commercial building.

The rent or sale of a residential part of the building shall be treated as zero-rated or exempt, depending on whether this is a first supply or a subsequent supply.

The rent or sale of a commercial part of the building shall be treated as subject to VAT at 5%.

The tax incurred by the owner on the building needs to be apportioned where there is an exempt supply, and the portion related to the taxable supply (at 0% and 5%) may be recovered.

The rent of a residential building will generally be exempt from VAT.

The rent of a commercial building will be subject to VAT at 5%

The VAT treatment of real estate will depend on whether it is a commercial or residential property.

Supplies (including sales or leases) of commercial properties will be taxable at the standard VAT rate (i.e 5%).

On the other hand, supplies of residential properties will generally be exempt from VAT. This will ensure that VAT would not constitute an irrecoverable cost to persons who buy their own properties. In order to ensure that real estate developers can recover VAT on construction of residential properties, the first supply of residential properties (through sale or lease) within 3 years from their completion will be zero-rated.

The rent or sale of a residential part of the building shall be treated as zero-rated or exempt, depending on whether this is a first supply within the first three years of completion of construction or a subsequent supply.

The rent or sale of a commercial part of the building shall be treated as subject to VAT at 5%.

Tax that cannot be directly attributed to exempt supplies or taxable supplies should be apportioned, and only the portion relating to the taxable supplies (at 0% and 5%) may be recovered

The Corporate Tax Law provides for certain restrictions on the deductibility of interest expenditure to discourage excessive debt financing, and to ensure that debt financing used or arising as a result of certain specific intra-group transactions will only be deductible if there is a valid commercial reason for obtaining the loan.
General interest deduction limitation rule:
Businesses with net interest expenditure above a threshold to be set by the Minister will be allowed to deduct net interest expenditure up to 30% of their earnings before interest, tax, depreciation and amortisation (EBITDA), excluding any exempt income. Any net interest expenditure which exceeds this limit may be carried forward and utilised in the subsequent 10 tax periods. 
Businesses with net interest expenditure below the threshold to be set by the Minister will not be subject to the general interest deduction limitation rule.
The general interest deduction limitation rule will not apply to banks and other finance institutions, insurance providers or individuals.
Specific interest deduction limitation rule:
Where a loan is obtained from a Related Party and is used to finance income that is exempt from CT, the interest on the Related Party loan will not be deductible unless the taxpayer can demonstrate that the main purpose of obtaining the loan and carrying out the transaction is not to gain a CT advantage.