As we move further into 2026, we extend our warm greetings and sincere appreciation to all our readers for their continued support and encouragement.
In an increasingly dynamic regulatory environment, staying informed on evolving tax and legal principles remains essential for businesses and professionals alike. With this objective, the present edition brings together discussions on two important areas involving international taxation and transfer pricing.
The first article examines the taxability of capital gains arising from mutual fund investments, with particular focus on the treatment applicable to non-resident investors under the provisions of the Income Tax Act, 2025 (Income Tax Act, 1961) and the relevant Double Taxation Avoidance Agreements. The discussion analyses the domestic tax framework governing various categories of mutual funds and further evaluates the treaty position in cases where the investor is a tax resident of the United Arab Emirates or the United States of America, and the article supported by relevant judicial precedents.
The second article discusses certain specialised transfer pricing situations that require careful consideration while determining whether related party arrangements satisfy the Arm’s Length Principle under the UAE Corporate Tax regime. It covers significant aspects relating to cost contribution arrangements, business restructurings, permanent establishments, group synergies, and other practical issues, while also highlighting important considerations in transfer pricing audits, risk assessments, and adjustments by the Federal Tax Authority.
Lastly, CBDT notifications for the month of January 2026 has been included in this wiki to ensure continual updating with the latest regulatory developments.
Key Topics:
- Taxation of Capital Gains on Mutual Funds: Domestic Law and Treaty Perspective
- Transfer pricing in UAE – Part VII
- CBDT notifications for the month of January 2026
