Date

 Session

                             Session Details

Speakers Name

(Day 1)

12th April, 2025

Saturday

 Session 1

Time: 10:00 AM to 1.15 PM (including 15 mins break) 

• Background and rationale of introducing CT in UAE 

Taxable income and Tax (UAE CT)

• What is ‘income’

• Capital gains and other capital receipts in
  terms of taxability (vs. Revenue receipts)

• Rules relating to Income exempt from Tax

• Rate of Corporate tax

• Taxable Year

• Manner of payment of tax and filing of tax return 

Expense deduction (UAE CT)

• Limitations

• Nondeductible expenses

• Accounting or Financial Treatment  

CA. Piyush Bafna, Pune

Session 2

Time: 2.15 to 5.30 PM (including 15 mins break) 

 Taxable persons

• Basis of taxation (resident vs non-resident)

• Legal persons

• When can a foreign entities be said to have a
  Permanent Establishment (PE) in UAE

• Foreign entities that are effectively managed and controlled in UAE

Natural persons engaged in business / commercial activity in UAE` 

• Person’s Not Covered by UAE CT

• Persons not covered by UAE CT 

• Private or family trust holding

• Exempt persons

• What are sovereign / mandated activities

• Focus on Investment funds and conditions for their exemption 

CA. Piyush Bafna, Pune

(Day 2)

13th April, 2025

Sunday

Time: (10.00 A.M – 05.30 P.M)

Session 1

Double Taxation

• Source and Residence Rules – Juridical Double Taxation

• Model Tax Conventions on Double Tax Avoidance -
  Brief introduction of Articles 

CA Vivek Shah, Mumbai

Session 2

Residential status and its relevance

• Worldwide taxation vs. Territorial taxation

• Worldwide taxation in case of Legal persons
  incorporated in UAE and Foreign entities with PoEM in UAE

• Territorial taxation of Natural persons

• Taxation of NRs and Income from PE

• Meaning of ‘UAE sourced income’

• Art. 4 of OECD MC (‘Resident’) 

CA Vivek Shah, Mumbai

(Day 3)

19th April, 2025

Saturday

Session 1

Permanent Establishment

• Concept of PE under Art. 5 of OECD MC (and under international context)

• Fixed Place PE and Agency PE (referred to in the Consultation Paper)

• Installation PE and Service PE (no referred to in the Paper)

• PE of FZ persons in Mainland – Implications

• Taxation of PEs – Attribution

• Article 7 of OECD MC  

CA. Rajesh Vaishanav, Hyderabad

Session 2

Place of Effective Management (PoEM)

• What is effective management

• Meaning under OECD MC and international jurisprudence

• Approach followed by specific countries

 Taxation of partnerships

• Understanding various approaches followed internationally,
  for taxation of partnership –
  Fiscally transparent vs. Separate entity approach

• Possibilities of double non-taxation – OECD Action Plan

• Approach under UAE CT

• Potential challenges

CA. Rajesh Vaishanav, Hyderabad

(Day 4)

20th April, 2025

Sunday

Session 1

Thin-Capitalization norms

• OECD’s approach towards Thin-cap norms

• Fixed ratio rule and Group ratio rule

• Intra-group borrowing and need for ‘Valid commercial reasons’

• Safe-harbor protection 

Certain incomes that are exempt

• Participation Exemption

• Dividend and Capital Gains – Shareholding in FZP

CA Gaurav Singhal, Delhi

Session 2

Taxation of Free Zone Persons (FZP)

• Incomes that are unconditionally exempt

• Regulated financial services directed at foreign markets

• Profit from Mainland branch (allocation of income and expenses)

• Transaction between FZP and its group company
  in Mainland UAE – Trade off

• Disqualification from 0% CT rate vs. Opting out of 0% CT rate 

Computation of taxable income

• Accounting profits

• Accounting standards and calculation of Accounting profits or losses

• Adjustment for exemptions, disallowances

• Unrealized gains / loss – Capital vs. Revenue items

• Thin-capitalization: Interest expense capping

Relief for small business / start-ups – Simplified financial and tax reporting

CA Gaurav Singhal, Delhi

(Day 5)

26th April, 2025

Saturday

Session 1

Offset of tax losses

• Meaning and mechanism of carry forward of tax losses

• Change in shareholding

• Losses that cannot be carried forward

Group taxation

• Concept of Group level tax consolidation (and conditions)

• Benefits and disadvantages

• Transfer of losses where there is no consolidation

Tax exemption / deferral for inter-company transfer of asset or liabilities

CA. Jai Kumar Tejwani, Delhi

Session 2

Corporate reorganizations

• Tax neutrality – International experience

• Tax exemption / deferral for transfer of business under share swap

• Cross-border corporate reorganizations 

Administration

• Registration and de-registration

• Filing, payment and refund

• Assessment

• Documentation requirements

• Transitional Rules

CA. Jai Kumar Tejwani, Delhi

(Day 6)

27th April, 2025

Sunday

Session 1

 Overview of articles of OECD MC

• Article 12 - Royalties and Fees for Technical Services

CA. Prerna Peshori, Pune

Session 2

Overview of articles of OECD MC

• Article 10 – Dividend

•  Article 11 – Interest

• Article 6 - Income from Immovable Property

CA. Prerna Peshori, Pune

(Day 7)

3rd May, 2025

Saturday

Session 1

 Overview of articles of OECD MC

• Article 13 - Capital Gains

Relief from double taxation

• Exemption vs. Credit Method

• Foreign Branch Profit exemption

• Foreign Tax Credit – Concept and computation

• FTC under DTAAs

CA. Sachin Sastakar, Pune

Session 2

• An Overview of Transfer Pricing

• Development of UAE CT Transfer Pricing Regulations

• Concept of  Functional Analysis

CA. Rishabh Agarwal, Delhi

(Day 8)

4th May, 2025

Sunday

Session 1

Comparability Analysis

• Selection or rejection of comparable

• Timing issues in comparability

• Arm’s length range

CA. Rishabh Agarwal, Delhi

Session 2

Comparability Analysis

• Multiple year data

• Location specific advantages (Including location
  savings and market premium)

• Comparability adjustments 

CA. Rishabh Agarwal, Delhi

(Day 9)

10th   May, 2025

Saturday

Session 1

Selection of Transfer Pricing Methods 

• Selection of most appropriate method 

CA Praneeth Narahari, Hyderabad

Session 2

Documentation and Drafting

• Transfer Pricing Study Report

• BEPS requirements Action Plan 13 - Concept of 3 tiered system –

  • Master File

  • Country by Country report

  • Local File

CA Praneeth Narahari, Hyderabad

(Day 10)

11th May, 2025

Sunday

Session 1

Overview of BEPS 

• BEPS 2.0 – Pillar 1 and 2

• Global minimum effective tax rate

Pillar 1 of BEPS 2.0

CA Swapnil Bafna

Session 2

Overview of BEPS

• Introduction to BEPS and its Action Plans

• Treaty Abuse and Treaty shopping

• Reading of DTAAs with the MLI (and relevance of synthesized text)

  • OECD and G20 inclusive framework on BEPS

CA Vasudevan G

(Day 11)

17th May, 2025

Saturday

Session 1

BEPS Action Plans 8-10: Aligning Transfer Pricing
Outcomes with Value Creation

• Transfer Pricing and Royalties and Services

• Business Restructuring

CA Somesh Agarwal, Pune

Session 2

 Dealing with controversies

 Potential challenges in UAE CT and TP

 MAP and APA

CA. Sachin Agarwal, Pune