30 August 2026 · MD 302/2024
What MD 302 of 2024 Changed
Ministerial Decision No. 302 of 2024 replaced MD 116 of 2023 and refined the participation exemption and foreign permanent-establishment exemption. Where you use the AED 4 million acquisition-cost route, the 5% ownership-linked tests are relaxed, and the asset-composition test applies only to Related-Party participations. It gives Dubai holding structures a more workable, predictable exemption.
Exiloz Management & Tax Consultant · Dubai-based FTA-focused advisory · VAT, corporate tax & accounting
What was refined
The 2024 decision improved the rules.
- Replaced Ministerial Decision 116 of 2023.
- AED 4m cost route relaxes ownership-linked tests.
- Asset test limited to related-party participations.
- Clarified different participation types.
Better for holding companies
A more usable exemption.
- More predictable qualification.
- Supports genuine Dubai holding structures.
- Aligns with the foreign PE exemption.
- Reduces uncertainty for investors.
Related guides
Frequently Asked Questions
For understanding the current rules.
What did MD 302 of 2024 replace?
It replaced Ministerial Decision 116 of 2023 on the participation and foreign permanent-establishment exemptions.
How does the AED 4m route change things?
Where you rely on the AED 4m acquisition-cost route, the 5% ownership-linked tests are relaxed.
Does the asset test still apply?
Yes, but mainly to related-party participations after the 2024 decision.
Can Exiloz apply the current rules?
Yes. We apply MD 302 of 2024 to your specific participation.
Apply the 2024 rules
Exiloz applies MD 302 of 2024 so your participation qualifies cleanly.