Treats an entity as located in the jurisdiction where it was at the start of the first day of the fiscal year when its location changes during that year.
What should you do now?Retain evidence of location at the year’s start and the change date and basis. Separately review registration updates and subsequent-year consequences.
What does the official Article provide?
The official source is Arabic. This English commentary is explanatory and is not presented as an official translation.
Treats an entity as located in the jurisdiction where it was at the start of the first day of the fiscal year when its location changes during that year.
This is a verified summary rather than a verbatim reproduction. Consult the official Arabic text, the Law and later decisions before making a final determination.
What does the Article mean in plain language?
Where an entity changes location during a fiscal year, this Article uses its location at the start of that year’s first day for DMTT purposes. It determines the jurisdictional placement for the year under computation; income is not automatically split between jurisdictions in proportion to months before and after the move.
First apply the Law’s location rules and, where needed, the dual-location rules, then establish the opening location and change date. The rule does not deny that a move occurred, determine residence for every other tax, or remove registration-update duties. A location change must also be distinguished from joining or leaving a group, which has separate rules.
Dual-resident entities, permanent establishments and groups with a location change during the year.
Retain evidence of location at the year’s start and the change date and basis. Separately review registration updates and subsequent-year consequences.
How can the rule appear in practice?
The entity’s year runs from 1 January to 31 December. It is located in the first jurisdiction at the start of 1 January and moves on 1 July. Under this rule, its location remains the first jurisdiction for that year, with procedural consequences of the move assessed separately.
This illustration is not an NBR case or a binding outcome for a particular fact pattern.Automatically splitting the year at the move date, or treating the opening-location rule as a release from registration updates.
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Before relying on the result
Is this Article enough on its own?
Usually not. Read it with the connected Law Article, definitions, any effective election and current NBR guidance, especially for an amount or deadline.
Does NBR guidance replace the Regulations?
No. Guidance explains application and supports procedures and examples, but current legislation and decisions prevail in case of inconsistency.