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Practical guide

ESR filing

If your company carries on a Relevant Activity, you must file a notification and, where the activity generates income, a full report demonstrating adequate substance in the UAE. Penalties attach to failing to file even where the substance itself is perfectly adequate.

In practice

Economic Substance Regulations filing

What a Relevant Activity is

A defined list: distribution and service centre, headquarters, holding company, intellectual property, shipping, banking, insurance, investment fund management, lease-finance. Holding company business catches far more entities than people expect, which is why ESR surprises so many otherwise well-run structures.

What adequate substance means

Adequate people, adequate premises and adequate expenditure in the UAE, with core income-generating activities actually conducted here and directed and managed from here. A company whose decisions are taken abroad does not have substance, whatever its address says.

Notification
Report
Relevant Activities
Substance test
The obligations, in the order they bite.
Notification
Filed within the prescribed period after the financial year end
Report
Required where the Relevant Activity generates income
Relevant Activities
Nine defined categories, including holding company business
Substance test
People, premises, expenditure, and direction and management in the UAE
Penalties
For failing to notify, failing to report, and for failing the test
Exempted persons
Certain categories, but exemption must still be claimed and evidenced
What to watch. Holding company business is a Relevant Activity, and a great many companies holding shares in subsidiaries have never considered ESR at all. If your structure includes a holding entity, assume it is in scope until you have confirmed it is not.

The sequence

How it runs.

  1. Determine whether you carry on a Relevant Activity

    Based on what you actually do, not on your licensed activity list.

  2. File the notification

    Within the prescribed window after the financial year end.

  3. Assess substance honestly

    Directors, employees, premises and expenditure in the UAE.

  4. File the report

    Where the activity generated income in the period.

  5. Fix the substance if it is thin

    Cheaper before an assessment than after.

Questions

Economic Substance Regulations — rules requiring companies carrying on defined Relevant Activities to demonstrate adequate economic substance in the UAE, through a notification and, where income is generated, a full report.

Any licensee carrying on a Relevant Activity, which includes distribution, headquarters, holding company, intellectual property, shipping, banking, insurance, fund management and lease-finance business.

Penalties apply for failing to notify, failing to submit a report, and for failing the substance test itself. The filing penalties apply even where the substance would have been adequate.

One question

Where are you in this?