The UAE Federal Tax Authority (FTA) has issued Decision No. 2 of 2025, updating the Policy on Issuing Clarifications and Directives. This document regulates the procedures for issuing tax clarifications, administrative exceptions, input tax apportionment and advance pricing agreements (APAs).
The new decision modifies the previously established policy under FTA Decision No. 4 of 2024 and is set to take effect on March 1, 2025. While it has been published on the FTA's website, it has not yet been published in the Official Gazette.
The revised Policy reflects changes in tax legislation, including:
- The global Pillar Two initiative and the introduction of a 15% minimum tax (Top-Up Tax) for multinational corporations with revenues exceeding €750 million,
- The growing role of Advance Pricing Agreements (APAs), which allow companies to preemptively agree on transfer prices with tax authorities, avoiding unexpected tax adjustments.
- The need for clearer criteria for issuing tax clarifications in the context of stricter transfer pricing regulations.
1. Private Tax Clarifications
The FTA may n...