Ministerial Decision No. 116 of 2023 for the purposes the Taxation of Corporations and Businesses stipulates the conditions to qualify for Participation Exemption. As per the Decision, ownership interest include and is not limited to, holding any one or a combination of Ordinary Shares, Preferred Shares, Redeemable Shares, Membership and Partner Interests, Other types of securities, capital contributions and rights that entitle the owner to receive profits and liquidation proceeds.
…To determine whether a Taxable Person has a Participating Interest, different types of ownership interests in the same juridical person shall apply and be aggregated. Further, ownership interests in the same juridical person held by members of a Qualifying Group in which the Taxable Person is a member shall be aggregated with those of the Taxable Person.
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