There are some Abu Dhabi Global Market (ADGM) Licensees that are exempt from the requirement to submit an ES Report and demonstrate Economic Substance in the UAE for the Reportable Period. The list includes the entities that are:

  • Entirely owned by UAE nationals or UAE resident individuals and that fulfill the conditions – one, it is not part of an MNE Group (as defined in the ESR), and two, it only operates in the UAE;
  • Investment Funds as defined in the Regulations;
  • Special purpose vehicles or an investment holding company or an Investment Fund as defined in the Regulations;
  • Tax resident in a jurisdiction besides the UAE;
  • A branch of a foreign company and all Relevant Income of the UAE branch is subject to tax in the jurisdiction of the foreign company.