FAQ
Frequently Asked Questions
Who is Affinitas FZCO, and who do you work with?
Affinitas FZCO is a Dubai-based premium advisory firm. We serve corporate and commercial clients, high-net-worth individuals, and family offices whose assets and interests span multiple jurisdictions. Our work is in the technically complex end of international tax, transfer pricing, ESR compliance, double taxation treaty analysis, and multi-jurisdiction holding structure design. We were the first firm authorised by DMCC to establish SPVs for clients. Our clients come to us through referral. We do not compete on price.
How do clients come to you, and how do we begin?
Most of our clients arrive through someone they trust. The first conversation is a private discussion of your circumstances and objectives — your structure, your jurisdictions, and the questions that do not have standard answers. From there we set out what we would do, and how.
To begin, we generally need identification, proof of residence, and an outline of the structure and activities involved. Banks and authorities may request further documentation on shareholders, beneficial owners, and directors. We are based at Fortune Tower, Jumeirah Lake Towers, Dubai.
Is an individual taxed in the UAE?
There is no personal income tax in the UAE. Corporate Tax applies to legal entities, not to individuals in their personal capacity. Where an individual carries on business under a licence, that activity may fall within the Corporate Tax regime — the distinction matters, and we assess it case by case.
How does UAE Corporate Tax apply, and at what rate?
UAE Corporate Tax applies to the profits of legal entities at 9% above AED 375,000, with the obligation beginning from the first financial year starting on or after 1 June 2023. A Qualifying Free Zone Person may access a 0% rate on its qualifying income, subject to conditions.
Whether an entity meets those conditions — and what its qualifying income actually is — is rarely a simple question. We assess it against the specific structure and activities.
When does a Free Zone entity qualify for the 0% rate (QFZP)?
A Free Zone Person that is a Qualifying Free Zone Person benefits from a 0% Corporate Tax rate on its qualifying income only. To qualify, it must:
- maintain adequate substance in the UAE;
- derive qualifying income, as defined under the Corporate Tax Law;
- not have elected to be subject to Corporate Tax at the standard rates;
- comply with the arm’s length principle and transfer pricing requirements; and
- meet any further conditions the Minister prescribes.
If any condition is not met, standard rates apply from the beginning of the tax period in which the entity fell out of compliance. Substance is where most claims are won or lost, and it is assessed through the Corporate Tax return — not separately. We structure with that in mind.
How does VAT apply in the UAE?
VAT applies at 5%. An entity whose taxable turnover exceeds AED 375,000 must register, file periodic returns, and keep records that withstand review. For multi-jurisdiction structures, the questions that matter are usually place of supply, intercompany transactions, and recovery — not the headline rate.
How do you approach transfer pricing?
Transfer pricing is central to how we work. We apply OECD methodology, benchmark intercompany transactions, and document them to the standard required by Ministerial Decision 97 of 2023 — Local File and Master File where the thresholds are met.
The objective is a position that is defensible under FTA audit, not one that merely files. We assess intercompany loans, reconcile them, and tell clients what the FTA will see before the FTA does.
How do double taxation treaties affect cross-border structuring?
The UAE’s double taxation treaty network is one of the reasons clients hold structures here. Treaty access affects withholding tax, the treatment of dividends and interest, and where profits are recognised. We work across this network — including the Russia–UAE treaty that entered into force in January 2026 — and design structures so that treaty positions hold up to scrutiny, not only on paper.
How do ESR and UBO obligations apply now?
The 2023 changes removed standalone ESR reporting to the Ministry of Economy — but they did not remove the substance requirement. Substance now lives inside the Corporate Tax return, and the FTA cross-references historical ESR positions against it. UBO obligations require accurate, maintained beneficial ownership records. We assess what the real exposure is — historical and current — rather than simply filing a form.
How do you handle AML and ongoing compliance?
Compliance is continuous, not a one-time filing. We help clients keep AML procedures, beneficial ownership records, and regulatory filings in order, and we keep structures audit-ready as obligations change. The aim is that nothing about the structure surprises a bank, an auditor, or a regulator.
What is the difference between an SPV and a Foundation?
An SPV (Special Purpose Vehicle) isolates and holds assets — shares, real estate, intellectual property — and ring-fences risk. A Foundation is a separate legal person used for wealth structuring, succession, and governance across generations. They solve different problems and are often used together. We were the first firm authorised by DMCC to establish SPVs, and we design holding and succession structures around what the assets and the family actually require.
Can a UAE entity act as a holding structure for assets and subsidiaries?
Yes. A UAE entity can hold shares in UAE and foreign companies, real estate, and other assets. The questions that matter are how dividends and gains are treated, whether qualifying income and treaty positions are preserved, and how the structure interacts with Corporate Tax. We design multi-jurisdiction holding structures with those interactions resolved from the outset.
How do you choose between a free zone and a mainland entity?
A free zone entity allows full foreign ownership and can access the 0% Corporate Tax rate where it qualifies. A mainland entity can contract directly across the domestic UAE market. The right choice depends on the activity, the counterparties involved, the Corporate Tax position, and banking — not on setup cost. We make the recommendation against your objectives, not a template.
How do you decide which free zone or jurisdiction is right?
There are more than forty free zones, and they are not interchangeable. We assess the choice across the dimensions that actually determine outcomes: the activity and how it is licensed; Corporate Tax and QFZP eligibility; economic substance; banking feasibility; and the structure’s long-term trajectory.
We start from your objectives, then align the licence, the bank account, and the operating requirements behind them. The output is a reasoned recommendation, not a catalogue.
Can a foreign company redomicile to the UAE?
In many cases, yes. A number of jurisdictions and UAE free zones permit a company to transfer its seat to the UAE while preserving its legal identity and history. Whether redomiciliation is the right route — or whether a new entity and a migration of assets is cleaner — depends on the existing structure, its contracts, and its banking. We assess both before recommending one.
What does your family office advisory cover?
We advise family offices on the structures that hold and protect family wealth across jurisdictions: Single Family Office structuring, the DIFC and ADGM regimes, holding and succession architecture, and the residency that supports it. The work is rarely about a single entity. It is about how the parts fit together, hold up to scrutiny, and pass to the next generation.
What does opening a UAE corporate bank account involve?
Banks assess the entity, its owners, and the substance behind it. Expect to provide passports, the trade licence, constitutional documents, beneficial ownership details, and a clear account of the activity and expected flows. The structure itself affects the outcome: a coherent, well-documented entity with genuine substance opens and operates an account far more smoothly than one assembled for cost alone. We prepare the file with the bank’s review in mind.
Can establishing a UAE entity support residency for you and your family?
Yes. Ownership or employment within a UAE entity can support residence visas for owners, key staff, and family, and we handle the process — including medical, Emirates ID, and dependants. Employment and investor visas typically run for two years; the Golden Visa offers longer terms for those who qualify. For internationally mobile individuals, we align residency with the wider structure rather than treating it as a separate errand.
Can purchasing UAE real estate support a residence visa?
Yes. A ready, fully paid property in Dubai above the qualifying value threshold set by the authorities can support a residence visa linked to that property; higher-value investment can support a longer-term Golden Visa. The thresholds change, so we confirm the current figures before you rely on them.
What standards do you work to?
We work to IFRS and GAAP for accounting, and to FSRA standards where the structure sits in ADGM. Transfer pricing follows OECD methodology. The point is not the acronyms — it is that the work holds up when a bank, an auditor, or the FTA examines it.
If your situation does not have a standard answer
That is the work we do. Speak to us.