UAE Corporate Tax Fundamentals/Interest Deduction Limitation
7 min

Article 30 Overview

Thin capitalisation rules under Article 30 — AED 10M cap or 30% of EBITDA.

Interest Deduction Limitation (Article 30)

The Rule

Net interest expense is deductible up to the lower of:

  1. AED 10 million per tax period, OR
  2. 30% of accounting EBITDA (earnings before interest, tax, depreciation, and amortisation)

What is Net Interest Expense?

Net interest expense = Interest income - Interest expense (if negative)

Example

Accounting EBITDA: AED 50,000,000
30% of EBITDA: AED 15,000,000
AED 10M cap: AED 10,000,000

Deductible limit: AED 10,000,000 (lower of the two)

If net interest expense is AED 12,000,000:
- Deductible: AED 10,000,000
- Excess: AED 2,000,000 (carried forward)

Carry-Forward of Excess

Excess interest that cannot be deducted can be carried forward to subsequent tax periods, subject to the same limitation.

Exemptions

  • Banks and financial institutions may be exempt
  • Cash pooling arrangements within a tax group
  • Entities below a de minimis threshold (AED 10M interest)

Key takeaways

  • Interest deduction capped at AED 10M or 30% of EBITDA
  • Excess interest can be carried forward
  • Banks may be exempt
Knowledge check

1. What is the interest deduction cap under Article 30?

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This lesson is general educational content, not individualized tax or legal advice. Always consult a qualified professional for your specific situation.