UAE Defines Non-Resident Tax Nexus for QIFs and REITs Under Cabinet Decision No. 35 of 2025, Triggered by 80% Income Distribution or Ownership Acquisition

A new framework has been issued to clarify when a non-resident entity having investments in the UAE may be considered to have a taxable presence under the country’s corporate tax regime. Cabinet Decision No 35 of 2025 sets out the rules for determining nexus for non-resident juridical investors in Qualifying Investment Funds (QIFs) and Real Estate Investment Trusts (REITs), replacing the previous Cabinet Decision No 56 of 2023. The decision also sits alongside Cabinet Decision No 34 of 2025, which targeted Qualifying Investment Funds and Qualifying Limited Partnerships more broadly. The overarching aim is to provide precise criteria for when non-resident investors become subject to UAE corporate tax under Federal Decree-Law No 47 of 2022, while maintaining an attractive investment climate and reducing unnecessary compliance burdens for foreign participants.

Table of Contents

Comprehensive overview of the decision and its context

Cabinet Decision No 35 of 2025 introduces a structured approach to determining nexus for non-resident juridical investors in two specific investment vehicles—QIFs and REITs. This framework is designed to delineate the boundary between investments that trigger UAE corporate tax obligations and those that do not, thus offering clarity to foreign investors, fund managers, and UAE-based entities that manage or oversee these funds. The decision reflects the UAE’s ongoing tax reform strategy and its intent to align with international tax standards, including efforts to prevent base erosion and profit shifting while preserving the country’s competitiveness as a destination for foreign capital.

Under the new rules, nexus refers to a taxable presence within the UAE, which in practical terms means that a non-resident investor could be liable for UAE corporate tax on profits connected to the QIF or REIT that create the nexus. The decision explicitly replaces the older standard established by Cabinet Decision No 56 of 2023, incorporating refinements that respond to evolving fund structures, cross-border investment patterns, and the regulatory landscape surrounding QIFs and REITs. The introduction of this decision follows the earlier issuance of Cabinet Decision No 34 of 2025, which concentrated on Qualifying Investment Funds and Qualifying Limited Partnerships, signaling a broader reform of how non-resident entities engage with the UAE’s tax regime.

This framework is anchored in the broader tax law regime that governs corporate taxation in the UAE, notably Federal Decree-Law No 47 of 2022 on the Taxation of Corporations and Businesses. The decision clarifies technical and factual thresholds that determine when nexus is triggered, providing a practical mechanism for tax administration, compliance planning, and cross-border tax risk management. For non-resident investors, the clarity offered by this decision helps delineate when they may be taxed on income linked to UAE-resident or UAE-managed QIFs or REITs, and when they are not considered to have a taxable presence simply by virtue of their investment structure.

The decision’s emphasis on clear distribution-based thresholds and ownership triggers reflects a policy preference for measurable, objective criteria over ambiguous or subjective assessments. In doing so, it aims to reduce compliance burdens for genuine non-residents who engage with QIFs or REITs in a purely investment-focused context while ensuring that UAE tax authorities can robustly identify and tax cases of genuine nexus resulting from economic activity within the UAE. This approach aligns with the UAE’s broader objective of maintaining an open, competitive, and well-regulated environment that supports foreign investment while protecting the integrity of its tax system.

How this fits with broader UAE tax reforms

The Cabinet’s 35/2025 decision does not operate in isolation. It interplays with the corporate tax regime, the design of investment funds, and the regulatory treatment of REITs, all while considering the details laid out in related decisions such as 34/2025. The combined effect of these instruments is to create a coherent framework in which non-resident investors can assess their potential UAE tax obligations in connection with QIFs and REITs. For fund managers and UAE-based fund sponsors, this coherence reduces the likelihood of inconsistent interpretations across different types of funds and investment structures, which in turn supports smoother cross-border investment flows and improved tax certainty for international participants.

The decision also reinforces the UAE’s position as a jurisdiction that offers clear rules, predictable outcomes, and robust governance around taxable presence. In an environment where international investors demand transparent and stable tax treatment, the cabinet’s decision contributes to a predictable tax landscape that supports long-term investment strategies. While the rules introduce nexus criteria, they are designed to be straightforward enough to be practically applied by taxpayers and tax administrators alike, with a focus on observable economic activities such as distributions and ownership changes within specified windows.

Key takeaways for stakeholders

The decision sets out explicit nexus criteria for non-resident juridical investors in QIFs and REITs.
It replaces earlier guidance and aligns with related cabinet initiatives to form a consistent tax framework for investment funds and real estate investment vehicles.
Nexus can arise through distribution-based triggers (80% or more of income distributed within nine months after the financial year-end) or ownership-based triggers (date of acquisition if distributions fall short of 80% within the same period).
A nexus may also be triggered if the QIF or REIT fails to meet diversity of ownership conditions during the relevant tax period.
Exclusive investment in QIFs and/or REITs does not automatically create a taxable presence, unless one of the specified nexus events occurs.
The framework aims to reduce compliance complexity while preserving the ability of UAE authorities to tax genuine economic activity within the UAE.

Nexus rules for non-resident investors in Qualifying Investment Funds (QIFs)

Qualifying Investment Funds are a central focus of the new framework, and the decision outlines two principal pathways for establishing nexus in a QIF. These pathways are structured around observable fund actions—specifically, how distributions are managed and how ownership changes occur within defined time frames.

First, a nexus is established on the date of the dividend distribution if the QIF distributes 80 percent or more of its income within nine months from the end of its financial year. This rule provides a clear, time-bound trigger tied directly to the fund’s operational performance and its allocation of earnings to investors. In practical terms, when a QIF achieves an 80 percent distribution threshold within the nine-month window, non-resident investors who hold interests in that QIF are considered to have a taxable presence in the UAE as of the distribution date. This creates tax exposure in respect of profits connected to that portion of distributions, aligning with the broader objective of taxing substantial in-country economic activity.

Second, a nexus arises on the date the ownership interest is acquired if the QIF fails to distribute at least 80 percent of its income within the same nine-month window. In other words, if the QIF does not meet the 80 percent distribution threshold, the act of acquiring an ownership stake—whether through initial investment, secondary purchases, or other qualifying acquisitions—triggers nexus. This ensures that a non-resident investor who acquires an interest in a QIF that under-distributes within the nine-month period is nonetheless brought within the UAE tax framework due to the potential for in-country economic activity associated with that investment.

In addition to these two main triggers, the decision introduces a further condition tied to the QIF’s governance over ownership structures. Specifically, a nexus is created if the QIF fails to meet the diversity of ownership conditions during the tax period in which the failure occurs. This provision recognizes that concentrated ownership patterns may reflect limited diversification and heightened in-country economic linkages, thereby possibly giving rise to a taxable presence in the UAE. The precise interpretation of “diversity of ownership” involves assessing the breadth and distribution of ownership interests among investors, including the geographic spread, investor type mix, and other factors that affect the likelihood of materially in-country activity.

Practical implications for QIF sponsors and investors

For QIF sponsors, the rules require careful monitoring of distributions and timely reporting to ensure that the fund’s actions are consistent with the nexus framework. If the fund plans to distribute 80 percent or more of its income within the nine-month window, it should anticipate that non-resident investors could be subject to UAE corporate tax from the distribution date onward. Conversely, if the fund anticipates distributions below the 80 percent hurdle, it must be prepared for nexus to arise on investor acquisition dates, which could occur at multiple points during the tax year as investors enter the fund.

Investors in QIFs should be aware that the date on which nexus attaches can vary depending on the fund’s distribution performance and the timing of their acquisitions. This underscores the importance of aligned tax planning, particularly for cross-border structures where investors may be subject to different tax treatments in their home jurisdictions. In corporate tax planning terms, the rules create a framework that incentivizes transparency around distribution policies and ownership diversification, as well as meticulous record-keeping for tracking dates that could trigger nexus.

Guidance for fund administrators and compliance teams

Establish robust tracking of distributions to confirm when the 80 percent threshold is achieved within nine months after the fund’s financial year-end.
Maintain precise records of ownership acquisition dates, including the timing of investor entries and any changes in ownership stakes, to determine nexus timing accurately.
Monitor ownership diversification by regularly assessing the fund’s investor base against defined diversity criteria and ensuring documentation to support compliance in case of an audit.
Coordinate with tax advisors to assess the tax consequences of nexus events for non-resident investors, including potential withholding obligations and the scope of UAE corporate tax in relation to QIF distributions and profits.
Update fund governing documents and offering materials to reflect nexus triggers and associated tax implications, ensuring that investors are informed about how nexus could affect their tax position.
Implement internal controls to detect near-threshold conditions, enabling proactive management of distributions and investor acquisitions to minimize unexpected nexus imposition.

Illustrative scenarios for QIF nexus

Scenario A: A QIF ends its financial year and distributes 85 percent of its income within nine months. In this case, any non-resident investor would be deemed to have a UAE tax nexus on the distribution date, provided the investor’s holdings correlate with the fund’s distribution. Tax planning would focus on understanding the tax treatment of those distributions in the investor’s home jurisdiction and any UAE-withholding requirements that may apply.
Scenario B: A QIF distributes only 60 percent of its income within the nine-month window. If an investor acquires an ownership stake during the same tax period, nexus would be established on the acquisition date, and the investor would potentially face UAE corporate tax on profits connected to that investment.
Scenario C: A QIF demonstrates a lack of diversity in ownership during the tax period (for example, a single investor or a very narrow group dominates the fund). The fund would trigger nexus under the diversity condition, regardless of distribution performance, prompting consideration of tax implications for all non-resident investors and the need for governance changes to restore diversification.

Balancing policy aims with practical realities

The QIF nexus rules are designed to create a predictable framework that aligns fund performance with tax outcomes. They recognize that substantial distributions within a defined period typically indicate in-country economic activity and a corresponding tax obligation. At the same time, they acknowledge that ownership changes can create nexus where distributions fall short of the threshold, ensuring that new investors cannot easily bypass UAE tax considerations by entering a fund simply to avoid tax exposure.

The diversity-of-ownership trigger adds an additional safeguard to prevent scenarios in which a fund concentrates ownership in a way that could obscure in-country activity from a tax perspective. The practical effect is to encourage fund managers to maintain broad and diverse investor bases, not only for compliance reasons but also for the overall governance and resilience of the investment vehicle. For non-resident investors, the rules provide a clear and objective basis for assessing the potential tax consequences of investing in a QIF, enabling more informed decision-making and proactive tax planning.

Nexus rules for Real Estate Investment Trusts (REITs)

The same core logic that governs QIFs also applies to REITs under Cabinet Decision No 35 of 2025, with adjustments to reflect the specific characteristics of real estate investment structures. In short, a REIT generates nexus for a non-resident investor under two complementary scenarios, mirroring the QIF framework: (i) a distribution-based trigger and (ii) an ownership-based trigger, both designed to capture substantive in-country economic activity and ownership dynamics.

First, a nexus arises on the date of the REIT’s dividend distribution if the REIT distributes 80 percent or more of its income within nine months from the REIT’s financial year-end. This distribution-centric trigger ensures that when a REIT pays out a substantial portion of its income to investors in a timely fashion, non-resident investors are considered to have a UAE tax presence on the distribution date. This approach mirrors the QIF’s distribution rule and is intended to promote parity across investment vehicles with similar income-distribution profiles.

Second, if the REIT fails to distribute at least 80 percent of its income within the nine-month window, the nexus is triggered on the date ownership interests are acquired. This ensures that new investors who take positions in under-distributing REITs are brought into the UAE tax framework from the date of their acquisition, reflecting potential in-country economic activity associated with their investment.

In addition to these two primary triggers, the decision includes a diversity-of-ownership provision for REITs. If a REIT fails to meet the diversity of ownership conditions during the tax period in which the failure occurs, a nexus is created. This provision emphasizes the importance of broad ownership dispersion in preventing artificial or concentrated ownership patterns that could distort in-country economic activity and obscure actual nexus.

Practical implications for REIT sponsors and investors

REIT sponsors must design and monitor dividend policies to understand whether distributions will meet the 80 percent threshold within the nine-month window. If the threshold is met, nexus arises for non-resident investors on the distribution date.
If distributions fall short of the threshold, attention shifts to ownership acquisition dates, with nexus arising at the moment a non-resident investor acquires an interest in the REIT.
The diversity-of-ownership rule applies to REITs as well, requiring ongoing governance oversight to ensure a broad and diverse investor base and to provide robust documentation if nexus is invoked during a tax period due to ownership concentration.
Investors in REITs should consider their entry and exit timing in relation to the nine-month distribution window and potential nexus implications. Tax planning should account for how UAE corporate tax applies to distributions and to underlying income that may be connected to the in-country activity associated with their REIT investments.

Illustrative REIT scenarios

Scenario D: A REIT distributes 82 percent of its income within nine months of the year-end. Non-resident investors would have nexus on the distribution date, so tax planning would focus on how UAE corporate tax would apply to the distributed profits, including any withholding mechanics and the investors’ cross-border tax positions.
Scenario E: A REIT distributes only 70 percent of income within the window. A non-resident investor who acquires an interest during the tax period would trigger nexus on the acquisition date, as the ownership-based trigger applies in this case.
Scenario F: A REIT’s ownership remains highly concentrated, failing the diversity-of-ownership conditions. Nexus could be triggered under the diversity rule, independent of the timing of distributions or acquisitions, prompting changes in governance and investor composition to mitigate tax risk.

Consistency with the broader tax framework

The parity between QIF and REIT nexus rules ensures consistent treatment for non-resident investors across these two investment vehicles. It also supports uniformity in compliance obligations for fund sponsors and managers, as well as clearer expectations for investors who compare investments across different fund types. The approach is aligned with the broader objective of the UAE corporate tax regime to tax substantive in-country activity while avoiding unnecessary tax exposure for genuine, non-resident investors who invest passively in the UAE through appropriately structured funds.

The diversity of ownership condition and its tax period implications

A distinctive feature of Cabinet Decision No 35 of 2025 is the explicit reference to diversity of ownership. This criterion recognizes that the way ownership is distributed among investors can influence the degree to which in-country activity is concentrated or dispersed, which, in turn, affects nexus in the UAE corporate tax context. The decision states that nexus may be created if a QIF or REIT fails to meet the diversity of ownership conditions during the tax period in which the failure occurs. This provision serves as a check against schemes that might aim to limit tax exposure by concentrating ownership in a narrow group of investors who may be less likely to trigger a broader nexus.

What constitutes diversity of ownership?

While the decision itself emphasizes the importance of diversity, it leaves room for interpretation against future guidance and regulatory practice. In practical terms, diversity of ownership could be assessed by examining factors such as:

The geographic distribution of investors, ensuring a mix of nationalities and jurisdictions.
The spread of ownership across different investor types (retail, institutional, sovereign wealth funds, family offices, etc.).
The concentration levels of ownership, with lower concentration indicating higher diversity.
The presence of cross-holdings or related-party relationships that could undermine genuine diversification.
The stability and turnover rate of investors, where high concentration among a few long-standing investors could be viewed differently from a broad, rotating investor base.

Implications for fund governance and compliance

Fund managers should implement governance practices that promote genuine diversification, such as limits on ownership concentration, regular reporting on ownership dispersion, and clear disclosure to investors.
Documentation supporting the diversity of ownership should be maintained to satisfy regulatory scrutiny and potential audits.
In cases where diversification is imperfect, fund managers may need to consider strategies to broaden the investor base to mitigate nexus risk, including marketing to a wider pool of international investors or adjusting fund terms to attract a broader mix of participants.
For non-resident investors, awareness of the diversity trigger is important in assessing potential UAE tax exposure, especially if they participate in funds with limited and concentrated ownership.

Timing and regulatory considerations

The diversity rule is tied to the tax period in which a failure occurs, which means that nexus considerations can arise not only from a fund’s performance or investor entry events but also from ongoing governance and ownership dynamics over time. This adds a forward-looking dimension to tax planning, reinforcing the need for ongoing compliance monitoring and governance adjustments to maintain or restore diversity levels.

Practical steps for compliance teams

Establish quantifiable metrics for what constitutes meaningful diversification in the context of the fund’s structure and investor base.
Conduct periodic reviews of the ownership mix, particularly after large investor inflows or outflows, mergers, or reorganizations.
Ensure that fund documentation reflects the diversification policy and any thresholds used to define diversity.
Prepare for potential nexus assessments by documenting divergence from diversity standards and outlining corrective actions, if any, to restore an acceptable level of diversification.

Implications for non-resident investors and tax compliance

The underlying policy objective of Cabinet Decision No 35 of 2025 is to delineate clearly when a non-resident investor becomes subject to UAE corporate tax in connection with QIFs and REITs, while maintaining a balanced, non-disruptive environment for foreign investment. The decision provides a more predictable income tax landscape by tying nexus to actionable fund performance metrics and ownership events rather than abstract concepts of presence or activity. It also ensures that non-resident investors are not inadvertently taxed merely by virtue of being an investor in a fund or real estate vehicle that does not meet specific distribution or diversification criteria.

Core implications for tax exposure

Nexus arising from distribution indicates that significant in-country economic activity is taking place through the fund, justifying UAE corporate tax on profits linked to that activity.
Nexus arising from ownership changes recognizes that new investors who acquire positions in under-distributing funds could contribute to UAE-based economic activity that should be taxed.
The diversification rule adds a governance and risk management dimension, discouraging overly concentrated ownership structures that could obscure in-country activity.

Compliance and reporting considerations

Non-resident investors should be aware of the precise dates that govern nexus triggers: distribution dates and ownership acquisition dates, as well as the tax-period timing when diversity conditions are evaluated.
Investors may need to assess whether their investment strategy could lead to nexus in the UAE despite a passive investment posture, and plan accordingly with tax advisors.
Fund sponsors should maintain consistent and transparent distribution policies, investor communications, and records that demonstrate compliance with the nexus framework.
Tax advisors will play a crucial role in helping investors determine potential UAE tax implications, including whether UAE corporate tax would apply and how any resulting tax obligations should be reported or withheld.

Limitations and considerations for exclusive QIF/REIT investments

The decision clarifies that non-resident juridical investors who exclusively invest in QIFs and/or REITs do not automatically have a taxable presence in the UAE. Instead, nexus arises only under the specified triggers or the diversity condition. This distinction is important for structuring investment portfolios and for tax planning, particularly for investors who have portfolios focused solely on these investment vehicles. It provides a level of assurance that passive participation within these funds is not presumptively taxable, while still giving authorities the tools to tax when substantive economic activity is present.

Operational and governance guidance for funds under the new framework

The introduction of nexus criteria for QIFs and REITs has practical implications for fund governance, operations, reporting, and investor communications. Directors and fund managers should integrate the nexus framework into fund policies and ensure cross-functional coordination across compliance, risk, finance, and investor relations teams.

Governance considerations

Update fund constitutions, offering documents, and internal policies to reflect nexus criteria and implications for non-resident investors.
Define clear distribution policies that align with the 80 percent threshold and the nine-month window, including documentation of distribution calculations and timing.
Establish controls to monitor ownership changes and assess whether these changes could trigger nexus, including trade settlement times, ownership records, and investor onboarding procedures.

Financial and reporting considerations

Implement robust systems to track distributions, including post-distribution confirmations and the calculation of whether the 80 percent threshold is met within the required window.
Maintain precise and auditable records for ownership acquisition dates, including the identities of investors, the dates of entry, and any subsequent changes in holdings.
Prepare regular internal and external reporting that reflects nexus-related considerations, enabling timely regulatory disclosures and investor disclosures where applicable.

Investor relations and communications

Provide clear communications to investors regarding the potential UAE tax implications of nexus events, including the timing of possible tax exposure and how distributions or ownership changes may affect non-resident investors.
Offer guidance on how nexus interacts with investors’ local tax positions and the potential need for tax planning advice in their home jurisdictions.

Risk management

Conduct regular risk assessments related to nexus triggers, including scenarios in which distributions are near the threshold or ownership concentration changes could shift Nexus status.
Develop contingency plans for fund restructurings or governance changes intended to diversify ownership and mitigate nexus risk.

Comparative context: UAE tax reforms and global alignment

Cabinet Decision No 35 of 2025 sits within a broader context of UAE tax reforms designed to create a stable, attractive environment for international investment, while ensuring compliance with international tax standards. The UAE has sought to establish a clear corporate tax framework under Federal Decree-Law No 47 of 2022, complemented by targeted cabinet decisions that address specific investment vehicles and fund structures. In this climate, the 2025 cabinet decisions work together to provide a cohesive set of rules governing nexus for non-resident entities and ensuring that the UAE tax system can respond effectively to complex cross-border investment arrangements.

From a global perspective, the UAE’s approach reflects a balance between competitive, business-friendly tax policy and the adoption of best practices in tax transparency and transfer pricing that international investors expect. The explicit nexus criteria for QIFs and REITs align with modern tax designs that emphasize the real economic activities tied to a taxpayer’s presence, while minimizing ambiguity for investors who participate in these investment platforms. This alignment signals to multinational investors that the UAE is serious about maintaining tax integrity in a global context without compromising its market competitiveness.

Transitional provisions, implementation timeline, and practical steps for stakeholders

As with most significant tax reforms, practical implementation requires attention to transitional provisions, timelines, and actionable steps for stakeholders. While Cabinet Decision No 35 of 2025 provides the rules, the specifics of effective dates, transitional relief (if any), and alignment with existing tax return cycles may be determined by accompanying regulatory guidance and administrative practices. Stakeholders should monitor official communications for clarifications on effective dates, transitional arrangements, and any guidance that clarifies how nexus would be applied in cross-border investment scenarios that involve preexisting holdings.

Implementation guidance for fund sponsors and managers

Review distribution policies to ensure alignment with the 80 percent threshold and nine-month window, including how distributions are calculated and reported.
Assess current fund configurations to evaluate the potential impact on existing non-resident investors and identify any actions needed to manage nexus exposure for new entrants.
Establish formal processes for tracking ownership acquisition dates, including onboarding documentation that captures the exact date of entry for each investor.
Develop internal controls to monitor diversity of ownership and take corrective actions if diversification metrics fall below defined thresholds.

Guidance for investors and tax professionals

Conduct a thorough assessment of whether existing positions in QIFs or REITs may trigger nexus under the new rules and how that nexus would affect UAE corporate tax exposure.
Work with local and international tax advisors to understand the interplay between UAE corporate tax, any withholding obligations, and the investors’ home-country tax regimes.
Plan investment timing and structuring to manage exposure, particularly for investors with significant cross-border tax obligations and complex fund portfolios.

Potential scenarios, case studies, and practical outcomes

To illustrate how the nexus rules operate in practice, consider a variety of scenarios that could arise under Cabinet Decision No 35 of 2025. These scenarios help investors, fund managers, and tax professionals anticipate outcomes and plan accordingly under the new framework.

Scenario G: A non-resident investor purchases a stake in a QIF that distributes 85 percent of its income within nine months. The nexus would arise on the distribution date, triggering UAE corporate tax obligations linked to the consequences of that distribution.
Scenario H: A REIT under-distributes, delivering only 70 percent within nine months. An investor acquiring a stake after the acquisition window could trigger nexus on the acquisition date if the fund has not achieved the distribution threshold. The timing would depend on the exact date of investment and whether the acquisition occurred before or after distributions.
Scenario I: A QIF shows insufficient diversity of ownership during a tax period. Even if distributions are compliant with the 80 percent threshold, nexus could be triggered due to lack of diversity, prompting tax considerations and governance action to broaden the investor base.
Scenario J: An investor holds interests in multiple QIFs and REITs. Each investment vehicle would be evaluated separately for nexus, with the potential for a composite tax position depending on the specifics of distributions, ownership changes, and diversity across all funds.

These scenarios demonstrate how the nexus framework interacts with distribution policies, acquisition timing, and ownership structure. They underscore the need for careful planning, robust record-keeping, and proactive governance to anticipate tax exposures and manage them effectively.

Conclusion

Cabinet Decision No 35 of 2025 introduces a detailed, structured framework for determining nexus for non-resident juridical investors in Qualifying Investment Funds and Real Estate Investment Trusts within the UAE. By establishing explicit nexus triggers—based on distribution thresholds within a nine-month window, ownership acquisition timing when distributions fall short, and the diversity of ownership during the relevant tax period—the decision provides clarity for foreign investors and fund managers while reinforcing the UAE’s commitment to a transparent, competitive tax environment. The coordination with related cabinet decisions and the broader corporate tax regime ensures a coherent approach that aligns fund governance, investor relations, and tax planning with the country’s reforms.

For non-resident investors, the framework distinguishes between passive participation in QIFs and REITs that do not trigger nexus and more active economic involvement that would give rise to UAE corporate tax obligations. This balance supports the UAE’s strategic objective of attracting foreign capital while maintaining robust tax compliance. Fund sponsors and managers must adapt governance processes, distribution policies, and investor communications to reflect the nexus criteria, implementing rigorous tracking, reporting, and diversification measures to manage nexus risk. Investors should engage with tax advisors to understand the implications for their specific holdings, considering how nexus timing could influence UAE tax exposure and the broader cross-border tax landscape.

As the UAE continues to refine its tax framework, stakeholders should anticipate further guidance on transition arrangements, interpretation of diversity of ownership, and potential future clarifications related to nexus in QIFs and REITs. By staying informed and aligned with the new rules, investors and fund managers can navigate the evolving regulatory environment with greater confidence, leverage the UAE’s competitive investment climate, and ensure compliance with the country’s corporate tax regime.