The UAE Ministry of Finance has announced the issuance of two key Cabinet Decisions aimed at updating and clarifying the tax regulatory framework applicable to investment structures and foreign investors under Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses:
- Cabinet Decision No. 34 of 2025 on Qualifying Investment Funds and Qualifying Limited Partnerships for the Purposes of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses (repealing Cabinet Decision No. 81 of 2023);
- Cabinet Decision No. 35 of 2025 on Determining the Nexus of a Non-Resident Person with the State for the purposes of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses (repealing Cabinet Decision No. 56 of 2023).
The Decision updates the conditions under which an investment fund may be recognized as a Qualifying Investment Fund (QIF), thereby granting it preferential treatment under the UAE Corporate Tax regime. It also introduces several important clarifications:
- Flexibility in meeting diversification requirements: Temporary brea...