Economic Substance Notification Filing in the UAE

Economic Substance Notification
Filing in the UAE

As part of the commitment of the United Arab Emirates as a member of the OECD Inclusive Framework, on 30 April 2019 the UAE presented a Regulations on Economic Substance (Cabinet of Ministers Resolution No.31 of 2019).

Article (1) of the ESR defines a Licensee as "any natural or juridical person licensed by the competent licensing authority in the UAE, to carry out a Relevant Activity in the UAE". A Licensee includes a commercial license, certificate of incorporation, or another form of permit required to be procured before the Licensee being able to carry out a Relevant Activity, thus, this includes Mainland Companies, Free Zone Companies, and Offshore Companies.

UAE ECONOMIC SUBSTANCE PROCESS

According to the ESR rules, all Licensees are required to notify the Regulatory Authority (typically the license issuing authority) annually on the following data:


  • Whether or not the Licensee is carrying on a Relevant Activity

  • If the Licensee is carrying on a Relevant Activity, whether or not all or any part of the Licensee's gross income concerning the Relevant Activity is subject to tax in a jurisdiction outside the UAE

  • The date of the end of the Licensee’s Financial Year (Accounting Reference Period)


Below you'll find the general interpretation of the economic substance flowchart that is based on combined understanding from UAE Ministry of Finance and several reputable UAE Free Zones.



UAE ECONOMIC SUBSTANCE PROCESS

According to the ESR rules, all Licensees are required to notify the Regulatory Authority (typically the license issuing authority) annually on the following data:


  • Whether or not the Licensee is carrying on a Relevant Activity

  • If the Licensee is carrying on a Relevant Activity, whether or not all or any part of the Licensee's gross income concerning the Relevant Activity is subject to tax in a jurisdiction outside the UAE

  • The date of the end of the Licensee’s Financial Year (Accounting Reference Period)


Below you'll find the general interpretation of the economic substance flowchart that is based on combined understanding from UAE Ministry of Finance and several reputable UAE Free Zones.



ECONOMIC SUBSTANCE REGULATIONS RELEVANT ACTIVITIES

According to The UAE Economic Substance Regulations Relevant Activities Guide businesses with the following activities should review and comply with the requirements of the ESR:


RELEVANT ACTIVITYSPECIFIC CORE INCOME GENERATING ACTIVITIES (CIGA)
Banking Business
  • Raising funds, managing risk including credit, currency and interest risk

  • Taking hedging positions

  • Providing loans, credit or other financial services to customers

  • Managing capital and preparing reports to investors or any government authority with functions relating to the supervision or regulation of such business

Insurance Business
  • Predicting and calculating risk

  • Insuring or re-insuring against risk and providing Insurance Business services to clients

  • Underwriting insurance and reinsurance

Investment Fund Management Business
  • Taking decisions on the holding and selling of investments.

  • Calculating risk and reserves

  • Taking decisions on currency or interest fluctuations and hedging positions

  • Preparing reports to investors or any government authority with functions relating to the supervision or regulation of such business

Lease-Finance Business
  • Agreeing on funding terms

  • Identifying and acquiring assets to be leased (in the case of leasing)

  • Setting the terms and duration of any financing or leasing.

  • Monitoring and revising any agreements

  • Managing any risks

Headquarter Business
  • Taking relevant management decisions

  • Incurring operating expenditures on behalf of group entities

  • Coordinating group activities

Shipping Business
  • Managing crew (including hiring, paying and overseeing crew members)

  • Overhauling and maintaining ships

  • Overseeing and tracking shipping

  • Determining what goods to order and when to deliver them, organizing and overseeing voyages

Holding Company Business Activities related to a Holding Company Business
Intellectual Property Business
  • Taking strategic decisions and managing (as well as bearing) the principal risks related to the development and subsequent exploitation of the intangible asset generating income

  • Taking the strategic decisions and managing (as well as bearing) the principal risks relating to the acquisition by third parties and subsequent exploitation and protection of the intangible asset

  • Carrying on the ancillary trading activities

Distribution and Service Centre Business
  • Transporting and storing parts, materials or goods ready for sale

  • Managing inventories

  • Taking orders

  • Providing consulting or other administrative services

Companies in which the Federal Government or Government of any Emirate of the UAE or any governmental authority or body of any of them holding at least 51% of direct or indirect ownership in its shareholding, will be exempt from Economic Substance Regulations in the UAE. Any Licensee that is not owned by the UAE Government is required to meet the Economic Substance Test.

ECONOMIC SUBSTANCE REGULATIONS SUBMISSION DEADLINES

Below is presented the most updated information released by the Regulatory Authorities as to the deadlines and the procedures in which their Licensees must obligatory submit their respective ESR Notifications. UAE Free Zones that are not mentioned in the chart below did not provide the deadlines and instructions on ESR notification filing as of May 2020. For the latest information, please contact us accordingly.

AUTHORITY NOTIFICATION DEADLINE SUMMARY/ HOW TO APPLY
Dubai South (DS) 7th June 2020 Applicable to all Licensees that carry out a Relevant Activity.
Apply manually via email:
[email protected]
Dubai Aviation City Corporation (DACC) 7th June 2020 All Licensees must report to the Authority and confirm whether or not they carry out a Relevant Activity. See guidance and template for a notification here.
Apply manually via email:
[email protected]
Dubai International Financial Centre (DIFC) 12th June 2020 All DIFC entities are required to submit the ESR notification regardless of whether the entity conducts a Relevant Activity.
Apply manually via email:
[email protected]
Dubai Multi Commodities Centre (DMCC) 30th June 2020 All Licensees must report to the Authority and confirm whether or not they carry out a Relevant Activity.
See guidance and template for a notification here.
Apply via Authority Portal
Dubai World Trade Centre (DWTC) 30th June 2020 Applicable to all Licensees that carry out a Relevant Activity.
Apply manually via email:
[email protected]
Abu Dhabi Global Market (ADGM) 30th June 2020 Applicable to all Licensees carrying out a Relevant Activity, located in ADGM and whose financial year commences on or after 1 January 2019. See further filing guidance and form for notification.
Apply manually via email:
[email protected]
Ras Al Khaimah Economic Zone (RAKEZ) 30th June 2020 All Licensees must report to the Authority and confirm whether or not they carry out a Relevant Activity.
See filing guidance here.
Apply via Authority Portal
Ajman Free Trade Zone (AFZA) 30th June 2020 Guidelines yet to be published.
Apply manually via email:
[email protected]
Sharjah International Airport Freezone (SAIF) 30th June 2020 Applicable to all Licensees that carry out a Relevant Activity.
Apply via Authority Portal
Umm Al Quwain Free Trade Zone (UAQFTZ) 30th June 2020 All Licensees must report to the Authority and confirm whether or not they carry out a Relevant Activity.
Apply manually via email:
[email protected]
For Mainland Companies:
Department of Economic Development (DED)
30th June 2020 Applicable to all Licensees that carry out a Relevant Activity.
Apply via Authority Portal
For Offshore Companies:
Ras Al Khaimah International Corporate Centre (RAKICC)
30th June 2020 All Licensees must report to the Authority and confirm whether or not they carry out a Relevant Activity. The form for notification is available to Registered Agents only and is only for guidance purposes

Note:
* Penalty for late submission of the ESR Notification is AED 10,000 to AED 50,000
and for subsequent non-submission, it ranges up to AED 300,000.

** Notifications should be filed at the time specified by the Regulatory Authority and in the form and the manner approved by the Regulatory Authority.

HOW TO GET READY FOR ESR REPORTING

ESR Substance Report instruction and template for report submission are not yet provided by MOF as off May 2020, however, a Licensee must prepare in advance to ensure that they meet the Economic Substance Test according to regulations. Below are listed the key requirements of the Economic Substance Test.


Appropriately and directly managed in the UAE
  • At least 1 quorate board meeting per year, minutes signed and kept in the UAE and Key Strategic Decisions taken in the UAE

  • Qualified Directors in the UAE

Core Income Generating Activities (CIGA) are conducted in the UAE
  • The activity should show genuine activity in the UAE

Employees in the UAE
  • A satisfactory number of qualified employees who are physically present in the UAE (or adequate expenditure on outsourcing)

Operating Expenditure in the UAE
  • Satisfactory operating expenditure in the UAE (or adequate expenditure on outsourcing)

Physical Assets in the UAE
  • Satisfactory physical assets in the UAE (or adequate expenditure on outsourcing)


Note:
* In outsourcing, Licensee must ensure that 3rd party service providers are permitted, providing that the entity has sufficient control over the third party. Depending on Relevant Activity, the test can either be reduced or extended.

** Fines of up to AED 300,000 and possible license suspension, deregistration or even compulsory liquidation will apply for failure to meet the mandatory substance requirements.

HOW WE CAN ASSIST IN ESR NOTIFICATION FILING

As a leading corporate service provider in the UAE, My Business Consulting DMCC is here to assist you to define at which extend Economic Substance Regulations apply to your business, provide expert advice on ESR Notification Filing to help you comply with all ESR requirements and avoid non-submission and penalties.

Considering that basically, all UAE entities should assess whether they fall under the UAE Economic Substance rules (as per 2019 financial year), we can help entrepreneurs define which of the below compliance obligations company may have:

Our trained experts can assist you in Economic Substance Regulations Notification Form filing, providing clarification of the new government ESR criteria depending on the sector-specific business activity and guide you on the Compliance with ESR in the United Arab Emirates.

If you have any questions, please, contact us today to get a professional free advice at [email protected].

ECONOMIC SUBSTANCE REGULATIONS FAQ

UAE Ministry of Finance published Frequently Asked Questions on Economic Substance. The FAQs clarify certain aspects of the application of the Economic Substance Regulations and the Guidance on the Regulations. We’ve gathered key highlights of the FAQs in the summary below:

1Why has the UAE introduced Economic Substance Regulations?
The UAE introduced Economic Substance Regulations to honor the UAE's commitment as a member of the OECD Inclusive Framework on BEPS and in response to a review of the UAE tax framework by the EU which resulted in the UAE being included on the EU list of non-cooperative jurisdictions for tax purposes (EU Blacklist). The issuance of the Economic Substance Regulations on 30 April 2019 (the Regulations), and the subsequent release of the Guidance on the application of the Regulations on 11 September 2019, was a requirement for the removal of the UAE from the EU Blacklist on 10 October 2019. The purpose of the Regulations is to ensure that UAE entities that undertake certain activities are not used to artificially attract profits that are not commensurate with the economic activity undertaken in the UAE.
2What is the first reportable Financial Year?
The Regulations apply to financial years starting on or after 1 January 2019.

Example 1: A UAE company with 1 January 2019 - 31 December 2019 financial year – First assessable period would be 1 January 2019 - 31 December 2019.
Example 2: A UAE company with 1 April 2019 - 31 March 2020 financial year – First assessable period would be 1 April 2019 - 31 March 2020. No need to comply with the Regulations for the period 1 January 2019 - 31 March 2019.
3Who are the “Regulatory Authorities”?
The Regulations are administered by the Regulatory Authorities listed in Cabinet Resolution No (58) of 2019 Determining the Regulatory Authorities Concerned with the Business Mentioned in Cabinet Resolution No (31) of 2019 Concerning Economic Substance Regulations.
4Who is subject to the Regulations?
The Regulations apply to UAE onshore and free zone companies, branches, partnerships, and other UAE business forms (referred to as Licensees) that carry out any of the following Relevant Activities:

  • Banking Businesses

  • Insurance Businesses

  • Investment Fund Management Businesses

  • Lease-Finance Businesses

  • Headquarter Businesses

  • Shipping Businesses

  • Holding Company Businesses

  • Intellectual Property Businesses

  • Distribution and Service Centre Businesses

5What does it mean to be subject to the Regulations?
For each financial period in which a Licensee earns income from a Relevant Activity, it will need to meet an Economic Substance Test with that activity. The Economic Substance Test requires a Licensee to demonstrate that:

  • the Licensee and Relevant Activity are being directed and managed in the UAE;

  • the relevant Core Income Generating Activities (CIGAs) are being conducted in the UAE; and

  • the Licensee has adequate employees, premises, and expenditure in the UAE. In addition to an annual notification requirement, Licensees that undertake and earn income from a Relevant Activity are also required to file an Economic Substance Return within 12 months from the end of the relevant financial period (see Administration).

6Do the Regulations only apply to UAE entities that are part of a foreign multinational group, or that are owned by a foreign shareholder?
No. The Regulations impose economic substance requirements on any UAE entity which carries on a Relevant Activity, regardless of whether the UAE entity belongs to a foreign multinational group. However, a UAE based Distribution Business, Service Centre Business, Headquarter Business or High-Risk IP Business would only be within the scope of the Regulations if the UAE entity transacts with foreign group companies. Distribution, Service Centre, Headquarters, and High-Risk IP activities where transactions between UAE entities are not subject to economic substance requirements.
7Is a company registered under an ‘offshore’ free zone company regime subject to the Regulations?
Yes, if the “offshore” company undertakes a Relevant Activity.
8Do the activities listed on the commercial license determine whether a Licensee undertakes a Relevant Activity?
No. Whilst the commercial license may indeed state the Relevant Activity, a "substance over form" approach must be used to determine whether a Licensee undertakes a Relevant Activity and is within the scope of the Regulations. This means looking beyond what is stated on the commercial license to the activities undertaken by the Licensee during a financial period.
9Who is exempt from the Regulations?
Licensees that are directly or indirectly at least 51% owned by the Federal or an Emirate Government, or a UAE Government body or authority, are exempt from the Regulations.
10What if a Licensee does not undertake a Relevant Activity during a financial period?
If a Licensee does not undertake a Relevant Activity during a financial period, it does not need to meet the Economic Substance Test. The Licensee would not be required to notify its Regulatory Authority or submit an Economic Substance Return for the relevant financial period.
11What if a Licensee undertakes a Relevant Activity, but does not earn any income from that activity during a financial period?
A Licensee that undertakes a Relevant Activity but that does not earn income from this activity in a financial period is not required to meet the Economic Substance Test for that period. Whilst the Licensee would still need to submit a notification with its Regulatory Authority, it is not required to file an Economic Substance Return for the relevant financial period.
12If all income from the Relevant Activity is earned from outside the UAE, is the Licensee exempt from the Regulations?
No, this Licensee is not exempt from the Regulations. Income from a Relevant Activity for which the Licensee needs to demonstrate economic substance in the UAE includes all income, including income that is generated by the Licensee outside of the UAE.
13What can a Licensee outsource?
A Licensee can outsource any or all of its CIGAs so long as the outsourced activities are performed in the UAE. Effectively, this means that a Licensee can use UAE based employees and physical assets (including premises) of third parties or related entities to satisfy the Economic Substance Test. A Licensee cannot outsource “directed and managed”, as the Licensee is required to demonstrate oversight and control of its Relevant Activity in the UAE.
14To whom can a Licensee outsource?
A Licensee can outsource, contract, or delegate CIGAs to related parties or third-party service providers, as long as the Licensee monitors and retains the ability to control the outsourced activities.
15What should a Licensee do under an outsourcing arrangement?
A Licensee should:

  • Have adequate supervision of the outsourced activity; and

  • Ensure the outsourced activity is conducted in the UAE; and

  • Ensure the outsourcing provider has adequate substance in the UAE; and

  • Ensure there is no double-counting of the outsourcing providers' resources. The above can be evidenced through contractual agreements that govern the relationship and responsibilities of each party.

16Can a Licensee outsource any of its activities to a foreign person?
Activities that are not CIGAs (e.g. back-office functions) can be outsourced to related parties or third-party service providers that are located outside the UAE without adversely impacting the economic substance of the Licensee in the UAE.
17What is the "Distribution and Service Centre" Business?
A “Distribution and Service Centre” Business refers to two distinct activities that are covered under one “Relevant Activity” heading. A UAE entity is considered engaged in a Distribution Business if it:

  • Purchases goods from a Foreign Connected Person; and

  • Import those goods into the UAE; and

  • Distributes those goods outside the UAE. A UAE entity is considered engaged in a Service Centre Business if it:

  • Provides services to a Foreign Connected Person; and

  • Those services are in connection with the Foreign Connected Person's business outside the UAE. The economic substance requirements for a Distribution and Service Centre Business apply to UAE entities whose main activity is distribution and/or service center operations. Licensees engaged in Banking, Insurance, Investment Fund Management, Lease-Finance, Shipping, or Headquarter Business may also purchase goods for, and/or provide services to foreign group companies as a normal part of their business operations. To prevent duplicate reporting, such Licensees are not also considered engaged in a Distribution and Service Centre Business. UAE entities that purchase and sell goods from and to third parties, or that provide services to third parties, are not subject to the Regulations (as a Distribution and Service Centre Business).

18What is Holding Company Business?
A UAE entity is considered engaged in a Holding Company Business if it:

  • Only holds equity interest(s) in juridical person(s); and

  • Only earns dividend and capital gains from its equity interest(s) A UAE entity that holds other assets or earns other forms of income will not be considered a Holding Company Business. Where the holding of such other assets or the performance of other commercial activities constitutes a different "Relevant Activity" (e.g. a Lease-Finance Business), the UAE entity would be subject to the Regulations in respect of that other Relevant Activity.

19Are investment funds subject to the Regulations as a Holding Company Business?
No, an investment fund is not considered a Holding Company Business.
20Does a Holding Company Business need to demonstrate economic substance?
Yes, however, a Holding Company Business is subject to reduced substance requirements as follows:

  • Comply with existing reporting/compliance requirements under the regulations applicable to the Licensee; and

  • Have adequate employees and physical assets (e.g. premises) A Holding Company Business is not required:

  • to be “directed and managed” in the UAE (unless otherwise provided for under the rules and regulations of any Regulatory Authority’s); or

  • To have/demonstrate adequate expenditure in the UAE.

21What are the conditions for an IP Business to be considered as “High Risk”?
Either Condition A or B as set out below must be met for an IP Business to be considered as “High Risk".

Condition A: All of the following need to be met:

- The Licensee did not create the IP asset which it holds for its business;
- The Licensee acquired the IP asset either from:

  • A Connected Person, or

  • in consideration for funding research and development by another person situated in a country other than the UAE;

- The Licensee:

  • Licenses the IP asset to one or more Connected Persons, or

  • otherwise generates income from the asset in consequence of activities performed by Foreign Connected Persons.

Condition B: The Licensee does not carry out research and development, or branding, marketing, and distribution as part of its UAE Core Income-Generating Activity.
22What does it mean if a Licensee has a “High Risk” IP Business?
  1. Information is automatically shared with the foreign competent authority of the parent company, ultimate company, and ultimate beneficial owner; and

  2. The Licensee is presumed to not meet the Economic Substance Test unless the Licensee meets the increased substance requirements. The increased substance requirements require a High-Risk IP Licensee to demonstrate (and submit proof) that:


    • It has (had) a high degree of control over developing the IP asset; and

    • It has adequate full-time employees with the necessary qualifications that permanently reside and perform their activities in the UAE - relevant employee information (e.g. experience, contracts, qualifications, etc.) would need to be provided; and

    • It has a business plan showing the reasons for holding the IP in the UAE; and

    • Relevant decision making has and continues to take place in the UAE.

23What is a UAE Investment Fund Management Business?
A UAE entity that provides discretionary investment management services to Collective Investment Vehicles located in the UAE or a different jurisdiction. An Investment Fund Management Business includes making the discretionary investment, divestment, and risk-related decisions on behalf of an investment fund. UAE entities providing other types of investment fund related services such as fund administration, investment advisory, and custodian services are not considered engaged in an Investment Fund Management Business.
24What is Lease-Finance Business?
A UAE entity is considered engaged in a Lease-Finance Business if it provides credit or rents assets, equipment, or any other good to another person for consideration. Providing credit includes making loans and entering into other financing arrangements such as hire purchase agreements and finance leases. Licensees engaged in Banking, Insurance, and Fund Management Business may also perform lease or financing activities as a normal part of their business operations. To prevent duplicate reporting, such Licensees are not also considered engaged in a Lease-Finance Business and will not need to separately demonstrate economic substance in respect of any ancillary Lease-Finance activities.
25Is lending to another group entity considered a “Lease-Finance Business”?
Yes, a UAE entity that makes a loan or provides any other form of a credit to a UAE or foreign group company for consideration (e.g. interest) will be considered engaged in a Lease-Finance Business.
26Is investing and trading in debt securities considered undertaking a Lease-Finance Business?
No, UAE entities that invest and hold bonds and other debt securities that are traded on a regulated exchange are not considered engaged in a Lease-Finance Business.
27What if there is no consideration payable for the credit provided?
The Regulations do not apply to credit and other financing and leasing arrangements where there is no expectation of consideration in the form of interest, fees, rental payments, capital gains, or any other form of compensation. The grant of security in favor of the lender would not constitute consideration.
28What is the Headquarter Business?
A UAE entity that provides services to other foreign group entities, and through the provision of such services:

  • Has taken on the responsibility for the overall success of the group; or

  • Is responsible for an important aspect of the group’s performance.

29Does an entity need to be the ‘parent’ company to be considered a Headquarter Business?
No, a group’s corporate structure is not relevant in determining whether a UAE entity within the group is engaged in a Headquarter Business. Whether an entity is engaged in a Headquarter Business is entirely dependent on the nature of the services provided to foreign group companies.
30Can an entity be considered engaged in a Headquarter Business in addition to carrying on another Relevant Activity?
Possibly, if the Relevant Activities form two or more distinct business activities. However, if an activity that might otherwise fall within the definition of a Headquarters Business forms part of another main Relevant Activity of the Licensee, the Licensee would not be considered to also be engaged in a Headquarters Business. For example, a UAE subsidiary of a captive insurance group will not be considered to carry on a "Headquarter Business" simply because it assumes the material risk on behalf of the group.
31Who needs to notify and by when?
A Licensees that undertakes a Relevant Activity (irrespective of whether the Licensee qualifies for an exemption under the Regulations or has earned income from the Relevant Activity during the relevant financial period) need to submit a simple notification with its Regulatory Authority. Notifications for the financial period 2019 can be filed on or after 1 January 2020.
32Who needs to file an economic substance return and by when?
Only Licensees that earn income from a Relevant Activity during the relevant financial period and that are not exempt from the Regulations are required to demonstrate economic substance in the UAE and file an economic substance return. Economic substance returns must be filed within 12 months from the end of the relevant financial period.
33What are the penalties for non-compliance?
Failure to Notify: AED 10,000 to 50,000 Failure to provide accurate or complete information:

  • Penalty of AED 10,000 to 50,000; and

  • Deemed failure to demonstrate economic substance in the UAE Failure to demonstrate sufficient economic substance in the UAE for the relevant Financial Year: First failure - Penalty of AED 10,000 to 50,000; and

  • Information exchange with the foreign competent authority of (1) parent company, (2) ultimate parent company, and (3) ultimate beneficial owner. The second consecutive instance of failure

  • Information exchange with the foreign competent authority of (1) parent company, (2) ultimate parent company, and (3) ultimate beneficial owner; and

  • Penalty of AED 100,000 to 300,000; and

  • Trade / commercial license could be suspended, withdrawn, or not renewed.

34What should a Licensee consider before the end of a financial period?
The following is meant as a non-exhaustive list of matters a Licensee should consider (and action, where relevant) before the end of a financial period:

  • Assess what (if any) Relevant Activities it has performed during the financial period (applying a “substance over form” approach);

  • Assess the amount and type of income earned (if any) from the Relevant Activity during the financial period;

  • Hold board meetings with a quorum of directors physically present in the UAE;

  • Ensure board meeting minutes are signed and maintained in the UAE;

  • Identify the amount and type of expenses and UAE based assets (incl. premises) in respect of the Relevant Activity, and ensure access to assets (incl. premises) can be demonstrated (through agreements and financial records)

  • Identify the number of UAE based full-time employees or other personnel (and their qualifications) responsible for carrying on the Licensee’s Relevant Activity; and

  • Ensure control and supervision over any outsourcing arrangements can be demonstrated, e.g. through contractual agreements. Additional actions may be required to ensure a Licensee can demonstrate sufficient economic substance in the UAE for a relevant financial period, and the considerations above may differ where a Licensee has either a Holding Company or a High-Risk IP Business.

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