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Mardul Sharma

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  • Published: Apr 07 2025 05:47 AM
  • Last Updated: May 29 2025 11:49 AM

The UAE simplified corporate tax rules for foreign investors in QIFs and REITs, clarifying nexus determination and offering tax exemptions under specific conditions, aiming to boost foreign investment.


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The UAE Just Made Investing a Whole Lot Easier (For Some)

So, the UAE just dropped some major news on corporate tax rules, and honestly, it’s pretty significant for foreign investors. They've been tweaking things, and the latest changes – Cabinet Decisions No. 34 and 35 of 2025 – are shaking things up for non-resident investors in Qualifying Investment Funds (QIFs) and Real Estate Investment Trusts (REITs).

Less Tax Headache for QIFs and REITs?

The big deal? They've clarified when foreign investors are actually considered to be, for lack of a better term, "tax residents" in the UAE. Before, figuring that out was a real maze. Now, for QIFs and REITs that share at least 80% of their profits within nine months of their financial year-end, the tax connection only happens on the dividend payment date. Think of it as a massive simplification of the whole process.

What’s changed? Here's the lowdown:

  • Nexus for QIFs and REITs: It's either when the dividends are paid (if they meet that 80% distribution rule) or on the investment date (if they don't).
  • Real Estate Limit: If a QIF owns more than 10% in real estate, only 80% of that real estate income gets taxed.
  • Ownership Spread: If a fund doesn't have the right mix of owners, only the investors breaking the rules get hit, not the whole fund. That's a big relief!
  • A Little Breathing Room: QIFs get a grace period to fix ownership issues, as long as it's not over 90 days total each year.

Making the UAE More Attractive to Investors

Cabinet Decision No. 34 of 2025 is particularly good news for QIF investors. Income from a QIF is now tax-free in the UAE, as long as they follow the rules on real estate holdings and ownership diversity. Combine that with the simpler rules, and the UAE is suddenly looking a lot more appealing.

Following International Best Practices

These changes aren't just about QIFs and REITs either. They've also updated rules for Qualifying Limited Partnerships, letting some qualify for tax-transparent status – something that aligns with global standards. It shows the UAE is serious about making itself a global investment leader.

A New Chapter for Investment in the UAE?

The UAE is clearly trying to make things easier for foreign investors. By simplifying the tax rules, they're hoping to attract more investment and boost their economy. It’ll be interesting to see how this impacts the flow of capital into the country in the coming years. It’s a smart move, no doubt, and could significantly change the investment landscape.

FAQ

The UAE has simplified corporate tax rules, particularly for Qualified Investment Funds (QIFs) and Real Estate Investment Trusts (REITs). This includes clarifications on nexus determination and offers tax exemptions under specific conditions to encourage foreign investment.

The simplified rules and tax exemptions make investing in the UAE more attractive. Clearer regulations on nexus determination reduce uncertainty and streamline the investment process, leading to a more favorable investment climate.

QIFs are investment funds, and REITs are investment vehicles focused on real estate. The UAE's changes provide clearer tax guidelines for these structures, potentially reducing compliance complexities and boosting their appeal to foreign investors.

Nexus determination clarifies under what conditions a foreign entity is considered to have a tax presence (nexus) in the UAE. The simplification of these rules reduces ambiguity and makes it easier for foreign investors to understand their tax obligations.

The UAE aims to significantly boost foreign investment by creating a more transparent and attractive tax environment. These reforms are a key part of the UAE's broader economic diversification strategy.

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