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May 15, 2026

This decision fundamentally shifts the exemption model for Qualifying Investment Funds (QIFs), moving away from strict ownership diversity thresholds to a framework based on investor-level income adjustments. For investors in QIFs and REITs with significant immovable property income, 80% of this income is included in their taxable income. It also introduces exemption conditions for Qualifying Limited Partnerships (QLPs) engaged in Investment Business that do not derive income from UAE immovable property. This decision repeals Cabinet Decision 81 of 2023 for tax periods commencing on or after January 1, 2025, introducing greater tax neutrality.

[Applicable for Tax Periods commencing on or after 1 January 2025]
[Repeals Cabinet Decision No. 81 of 2023]

This is not an Official Translation:

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

Cabinet Decision No. 34 of 2025

Issued 27 Mar 2025 - (Effective from day following publication in the Official Gazette)

[GTL Notes]

The Cabinet:

Having reviewed the Constitution,
Federal Decree-Law No. 28 of 2022 on Tax Procedures, and its amendments,
Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses, and its amendments,
Cabinet Decision No. 81 of 2023 on Conditions for Qualifying Investment Funds for the Purposes of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses,
Pursuant to what was presented by the Minister of Finance and upon the approval of the Cabinet,

Decided:

Article 1 - Definitions

Definitions in Federal Decree-Law No. 47 of 2022 referred to above shall apply to this Decision, with the exception of that, the following expressions shall have the meaning assigned against each, unless the context requires otherwise: