Investment funds don’t operate like regular companies.
NAV calculations take time, audits run longer, property valuations are complex, and investor allocations often happen months after year-end.

Recognising these realities, the Federal Tax Authority issued FTA Decision No. 8 of 2025, effective for tax periods starting 1 January 2025.

This Decision establishes special compliance timelines for:

✔ Qualifying Investment Funds (QIFs)
✔ Real Estate Investment Trusts (REITs)
✔ Investors in QIFs/REITs
✔ Foreign investors with UAE nexus

This guide breaks down the Decision in simple language, with practical examples.

A QIF is an investment fund that meets exemption conditions under Cabinet Decision 34 of 2025 and becomes an Exempt Person for Corporate Tax.

Examples include:
• Real estate investment funds
• Private equity & venture capital funds
• REITs
• Infrastructure & debt funds

However, investors may still have filing obligations, depending on distributions and nexus.

The FTA introduced these rules for three main reasons:

1️⃣ Funds close their books late

Audits, NAV valuations, and investor allocations typically require 6–9 months.

2️⃣ Investors cannot calculate taxable income without fund data

Especially when funds hold UAE immovable property.

3️⃣ Foreign investors often trigger unintentional UAE nexus

Even through indirect holdings.

These timelines reduce penalties, clarify obligations, and align UAE practice with global fund taxation frameworks.

1️⃣ CT Registration Timelines for Investors (Article 2)

Foreign investors must register depending on the type of nexus triggered:

🔹 Clause 2 Nexus (UAE Immovable Property Income)

Deadline: 3 months

🔹 Clause 3 Nexus (Business Nexus / PE-Like)

Deadline: 12 months

📌 Example 1 — Clause 3 Nexus (12 months)

Investor A (UK company) holds 12% in a QIF
Fund FY end: 31 Dec 2025
Nexus: Clause 3
➡ Registration deadline: 31 December 2026

📌 Example 2 — Clause 2 Nexus (3 months)

Investor B (Cayman) indirectly acquires UAE property via a QIF on 1 July 2025
Fund FY end: 31 Dec 2025
➡ Registration deadline: 31 March 2026

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2️⃣ CT Return Filing for Investors (Article 3)

If an investor must adjust taxable income (for example, if 80% immovable property income was NOT distributed), the return is due on the later of:

✔ 12 months from fund FY end
✔ 9 months from investor FY end

📌 Example

Fund FY end: 31 Dec 2025
Investor FY end: 31 Dec 2025
Deadline comparison:
• 12 months → 31 Dec 2026
• 9 months → 30 Sep 2026

➡ CT Return due: 31 December 2026

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3️⃣ CT Payment Deadline (Article 3)

Same as filing:

➡ Later of 12 months (fund) or 9 months (investor)

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4️⃣ Funds Must Provide Information to Investors (Article 4)

Funds must provide:

(a) Income allocation details → Within 6 months

(b) 80% distribution confirmation → Within 9 months

📌 Example

Fund FY end: 31 Dec 2025
• Allocation details → 30 June 2026
• Distribution confirmation → 30 September 2026

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5️⃣ Exempt Person Declaration for Funds (Article 5)

QIFs/REITs that are exempt must submit the annual declaration:

➡ Within 10 months of FY end

📌 Example

FY end: 31 Dec 2025
Deadline → 31 October 2026

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6️⃣ Deregistration Rules for Investors (Article 7)

Investors must deregister if:
✔ They no longer have nexus
✔ AND they hold no QIF/REIT units for 12 months

Deadline: Within 3 months after the 12-month non-ownership period

📌 Example

Units sold: 1 Jan 2026
No ownership for 12 months → until 1 Jan 2027
Add 3 months → 1 April 2027

➡ Deregistration due: 1 April 2027

• QIFs and REITs follow special tax timelines, not standard ones
• Investors may have up to 12 months to file and pay CT
• Funds must provide allocation & distribution data within 6–9 months
• Foreign investors must monitor nexus carefully
• Deregistration rules apply only after 12 months of no unit holdings

🟦 Corporate Tax Timelines — QIFs & Investors (2025 Onwards)

Investors

• Clause 2 Nexus → Registration: 3 months
• Clause 3 Nexus → Registration: 12 months
• CT Return → Later of 12 months (fund) or 9 months (investor)
• CT Payment → Same rule
• Deregistration → 12 months without units + 3 months

Funds (QIF/REIT)

• Investor allocation data → 6 months
• 80% distribution confirmation → 9 months
• Exempt declaration → 10 months

If FY = 31 Dec 2025

• Data to investors → 30 Jun 2026
• 80% distribution → 30 Sep 2026
• Exempt declaration → 31 Oct 2026
• Investor filing/payment → 31 Dec 2026
• Deregistration (example) → 1 Apr 2027

We support:
✔ Fund managers (SCA / DFSA / FSRA regulated)
✔ Foreign investors in UAE property funds
✔ REIT investors
✔ Family offices & sovereign investors

Our services include:
• Corporate Tax registration
• Nexus assessment (Clause 2 vs Clause 3)
• Review of income allocation reports
• CT return filing
• Fund exempt declarations
• Investor deregistration
• Advisory on fund compliance & structuring