Page 13 - ICAI UAE TAX UPDATE_APRIL 2024
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Transaction           Fiscally Transparent                          Fiscally Opaque
       7.  Salary paid to    •   Not deductible in the hands of partners as    •   Not deductible as it is treated as
          partners              it is treated as amount withdrawn from the      profit distribution to the owner.
                                business.                                  •   Will not be taxable in the hands
                             •   Shall be included in the determination of       of partner as it is already taxed at
                                taxable income of the partner.                partnership level.
       8.  Reimbursement     •   such reimbursed costs would be deductible   •   Partnership can claim the deduction
          of expenditure to      by the partners in proportion to their distributive      of an amount reimbursed to the partner.
          partners              share.

                             •   The partners are allowed to set off their expenditure against the reimbursement.


       9.  Carry forward of   •   Not Relevant.                            •   The tax loss which is carried forward
          Tax Loss                                                            can only be utilized to offset the taxable
                                                                              income of the partnership and not
                                                                              the partners.
                                                                           •   No portion of the tax loss will be
                                                                              allocated to exiting partner.

       10. Foreign Tax Credit •   Is allocated among the partners in their    •   Credit can be availed by the
                                distributive share.                           partnership.

















































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