FTA clarifies director and officer definitions for Connected Persons tax compliance

The UAE Federal Tax Authority issued Corporate Tax Public Clarification CTP010 on 29 April 2026, clarifying how businesses must identify directors and officers under Article 36 of the UAE Corporate Tax Law. The clarification adopts a substance-over-form approach, meaning an individual's actual authority and responsibilities matter more than their job title. An officer may now include senior employees, general managers, authorized signatories, and persons with significant delegated authority. Directors are natural persons serving on the board of directors or equivalent governing bodies, including executive directors, non-executive directors, and alternate directors. Payments and benefits made to Connected Persons are only deductible if they are at market value and incurred wholly and exclusively for business purposes. Businesses must review their Connected Person identification process, remuneration arrangements, transfer pricing documentation, and Corporate Tax disclosures to ensure compliance.