The UAE continues to strengthen its Corporate Tax framework through the issuance of ministerial decisions that clarify compliance obligations and promote transparency.
In 2025, the Ministry of Finance (MoF) released several important directives under the Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses (“Corporate Tax Law”), providing additional guidance for taxable persons.
This article summarises and analyses two such decisions – Ministerial Decision No. 84, and No. 96 – that collectively enhance the regulatory landscape of UAE Corporate Tax.
Ministerial Decision No. 84 of 2025 – Audited Financial Statements
Issued: 25 March 2025 | Effective: 25 March 2025
The Ministry of Finance issued Ministerial Decision No. 84 of 2025 to define the categories of taxable persons required to prepare and maintain audited financial statements under Article 54(2) of the Corporate Tax Law.
This Decision replaces earlier guidance and establishes a more structured approach to financial reporting and audit compliance.
Scope of Application
The following entities are required to prepare and maintain audited financial statements:
- Taxable persons (not forming part of a tax group) whose annual revenue exceeds AED 50 million during the relevant tax period.
- Qualifying Free Zone Persons (QFZPs).
For tax groups, the Decision mandates the preparation of special purpose audited financial statements following the form, procedures, and rules issued by the Federal Tax Authority (FTA).
Additional Provisions
- Designated Zone distributors: QFZPs engaged in the distribution of goods or materials in or from a Designated Zone must comply with any additional procedures prescribed by the Authority.
- Non-resident persons: For non-residents, only revenue derived through Permanent Establishments or nexus in the UAE shall be considered for the AED 50 million threshold.
Repeal and Effective Period
- The Decision repeals Ministerial Decision No. 82 of 2023, which applied to earlier tax periods commencing before 1 January 2025.
- MD 84 of 2025 applies to all tax periods commencing on or after 1 January 2025.
Ministerial Decision No. 96 of 2025 – Real Estate Investment Trusts (REITs)
Issued: 14 April 2025 | Effective: 14 April 2025
This Decision builds upon Cabinet Decision No. 34 of 2025, which outlines the requirements for Qualifying Investment Funds and Qualifying Limited Partnerships.
Key Provision
For REITs listed for the first time on a Recognized Stock Exchange during the period from 1 May 2025 to 31 May 2025, the minimum public float requirement is 10%, instead of the higher percentage prescribed in Cabinet Decision No. 34 of 2025.
Applicability
The Decision applies to tax periods commencing on or after 1 January 2025.
Conclusion
These 2025 Ministerial Decisions show the UAE’s commitment to refining its Corporate Tax framework. Ministerial Decision No. 84 clarifies who must prepare audited financial statements and sets a specific revenue threshold. Ministerial Decision No. 96 supports real estate investment by offering a temporary, reduced public float requirement for certain REITs. Together, these measures provide businesses with regulatory clarity, strengthening the Corporate Tax Law.
