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UAE Cabinet Decision No. 209 of 2025 took effect on 30 January 2026, replacing the 2012 exchange-of-information framework. It imposes record-keeping and disclosure duties on UAE persons, including free zone entities, that apply whether or not the entity pays corporate tax, backed by fines up to AED 100,000.
The market read of UAE tax transparency runs through the Corporate Tax Law. A business asks whether it is a taxable person, whether it qualifies as a Qualifying Free Zone Person, whether it sits below the registration threshold, and treats the answer as the measure of its exposure to disclosure. Cabinet Decision No. 209 of 2025 on Exchange of Information upon Request for Tax Purposes breaks that link. Its obligations do not attach to a tax liability. They attach to the holding of information that a foreign tax authority might foreseeably request, and they apply to a person whether or not that person pays a dirham of UAE Corporate Tax.
The decoupling is in the text. Cabinet Decision No. 209 of 2025 defines "Person" and "Free Zones" independently of the definitions in the Corporate Tax Law. A Qualifying Free Zone Person taxed at 0% on its Qualifying Income, an entity below the Corporate Tax registration threshold, and an exempt person are each within the exchange-of-information regime on the same footing as a fully taxable mainland company. The obligation to maintain ownership, banking, accounting, and net-asset records, and to surrender them to the Ministry of Finance on a foreign authority's request, is not contingent on the entity's tax position. The free zone licence that determines the Corporate Tax outcome does not determine the exchange-of-information outcome.
This is the point that the corridor cohort most often misreads. A structure built to be tax-efficient in the UAE, holding investments or operating through a free zone vehicle at 0%, is frequently assumed to be low-profile because it is low-tax. Under Cabinet Decision No. 209 of 2025 the two are unrelated. The structure's ownership chain, its beneficial owners, its bank accounts, and its accounting records are all maintainable categories that the Ministry of Finance can require and exchange with a treaty partner that asks. The tax efficiency is intact; the opacity was never there.
Cabinet Decision No. 209 of 2025 entered into force on 30 January 2026, thirty days after its publication in the Official Gazette, and was announced by the Ministry of Finance on 10 February 2026. It replaces Cabinet Decision No. 17 of 2012, the prior enabling instrument, which authorised the exchange of information under treaties but imposed no direct compliance obligations on taxpayers, set out no enforcement mechanism, and carried no penalties. The 2025 Decision is the operational upgrade: defined obligations, defined record categories, defined retention, defined penalties, and a defined grievance route.
This article walks the statutory frame and the OECD Global Forum standard behind it, the decoupling from Corporate Tax, the record-keeping categories and the five-year retention, the competent-authority machinery, the penalty regime and the grievance process, the relationship between exchange on request and the automatic-exchange regimes (the Common Reporting Standard and the Crypto-Asset Reporting Framework), the five recurring traps we see in corridor files, and the sequencing with the rest of the UAE compliance stack and the UK side of the corridor. Exchange of information on request is not a tax. It is the standard against which the UAE's tax cooperation is peer-reviewed, and it now reaches every UAE person that holds information a partner might ask for.
The instrument sits at two layers: the international standard the UAE is measured against, and the domestic Decision that gives it effect.
The OECD Global Forum standard. The UAE joined the OECD Global Forum on Transparency and Exchange of Information for Tax Purposes in 2010, became a signatory to the Convention on Mutual Administrative Assistance in Tax Matters in 2017, and has concluded more than 140 bilateral double taxation agreements. The Global Forum operates a peer-review process that assesses each jurisdiction against the Exchange of Information on Request (EOIR) standard. The EOIR standard has three pillars: the availability of ownership and identity, accounting, and banking information; access by the competent authority to that information; and the exchange of it with treaty partners. A jurisdiction is rated on whether information is available, accurate, and accessible, and on whether its competent authority can obtain and transmit it without domestic obstacles. The recurring criticism in peer reviews of low-enforcement jurisdictions is that information may exist on paper but cannot be obtained effectively. Cabinet Decision No. 209 of 2025 is the UAE's answer to that criticism.
The domestic Decision. Cabinet Decision No. 209 of 2025 on Exchange of Information upon Request for Tax Purposes provides a single, comprehensive legislative framework for the EOIR standard. Under Article 3(1), the Ministry of Finance is expressly authorised, for the purposes of compliance with international treaties and agreements, to request and collect information and documentation, either directly or through government entities or regulatory authorities, and to exchange that information with competent foreign authorities upon their request, within the limits prescribed by the applicable international agreements. The Decision sets the categories of information to be maintained, the retention period, the powers of the competent authority and the regulatory authorities, the penalties, and the grievance process.
What replaced what. Cabinet Decision No. 17 of 2012 was the predecessor. It authorised the Ministry of Finance to collect and exchange information to fulfil treaty obligations, but it was an enabling instrument only: no direct taxpayer obligations, no enforcement mechanism, no penalties. Cabinet Decision No. 209 of 2025 converts the enabling power into an operational regime with statutory record-keeping duties, inspection and verification powers, administrative fines, and licence consequences. The shift is from a treaty-facing authority to a taxpayer-facing obligation.
On request, not automatic. EOIR is a request-driven mechanism. A foreign competent authority with which the UAE has a treaty or convention asks for information that is foreseeably relevant to the administration or enforcement of its own tax law, and the Ministry of Finance obtains and transmits it within the limits of the applicable agreement. This is distinct from automatic exchange, where financial-account or crypto data flows periodically without a specific request. The two operate together, and the relationship between them is developed below, but the obligation under Cabinet Decision No. 209 of 2025 is the duty to have the information ready and to surrender it when the request comes.
The single most consequential feature of Cabinet Decision No. 209 of 2025 for a corridor structure is that its scope is drawn independently of the Corporate Tax Law.
Who is in scope. The Decision applies to:
The express inclusion of free zone entities and licensed natural persons removes any argument that the regime is confined to mainland taxable companies. A free zone vehicle, a UAE-administered trust, and a licensed sole practitioner are each within scope.
Definitions independent of Corporate Tax. Certain key terms in Cabinet Decision No. 209 of 2025, including "Person" and "Free Zones", are defined independently of their counterparts in the Corporate Tax Law. The consequence is precise: the population of persons subject to exchange-of-information obligations does not track Corporate Tax classification, tax-residency status, or free zone tax treatment. An entity that is a Qualifying Free Zone Person at 0%, an entity that benefits from a Corporate Tax exemption, and an entity below the registration threshold are all fully within the exchange-of-information regime. Corporate Tax positioning is not an indicator of exchange-of-information obligations, and it should not be relied upon as one.
Obligation is not contingent on tax liability. The duty to maintain and provide information is linked to the potential relevance of that information to a foreign tax authority under an applicable treaty, not to whether the UAE person owes UAE tax. A holding entity that earns only exempt dividends, a free zone IP vehicle taxed at 0% on Qualifying Income, and a dormant company with a single bank account are each obliged to maintain the prescribed records and to surrender them on request. The regime treats the information as the trigger, and the information exists regardless of the tax outcome.
For the corridor, this is the reframing that matters. The UK side of a structure is already inside automatic exchange through the Common Reporting Standard and, from 2026, the Cryptoasset Reporting Framework. The UAE side was often assumed to be quieter because the UAE tax cost was lower. Cabinet Decision No. 209 of 2025 establishes that the UAE side carries a full information obligation that is independent of the UAE tax cost, and that a foreign authority can reach it on request through the UAE's treaty network. The Qualifying Free Zone Person analysis sets out the tax side of the free zone regime; the exchange-of-information regime sits over the top of it and does not move with it.
The operative obligation under Cabinet Decision No. 209 of 2025 is to maintain prescribed categories of information and to keep them for a defined period. The categories track the Global Forum EOIR standard.
Ownership and identity information. Persons in scope must maintain ownership and identity information, including beneficial ownership and the ownership chain. For a company, this is the register of shareholders, the beneficial owners exercising control through ownership or other means, and the chain of intermediate holders up to the ultimate beneficial owner. For a legal arrangement, it is the settlor, the trustees, the protector if any, the beneficiaries or class of beneficiaries, and any other person exercising ultimate effective control. The beneficial ownership emphasis aligns the regime with the UAE's separate beneficial ownership rules and with the AML framework, so that the information held for registry and AML purposes also supports a cross-border tax request.
Banking information. Persons must maintain banking information, including account-holder details and transaction records. Licensed banks carry enhanced obligations in respect of banking and ownership information, reflecting their position as the holders of the account data that an EOIR request most often seeks.
Accounting records. Persons must maintain accounting records sufficient to determine the financial position, including invoices, contracts, correspondence, ledgers, and financial statements. This is the category that makes the regime an accounting-records standard as much as an ownership standard: the records that substantiate the entity's transactions and results are precisely what a foreign authority asks for when testing a counterparty's reported position. Licensed natural persons must maintain accounting and asset records relating to their commercial activities.
Information on net assets. Persons must maintain information on net assets, including movable and immovable property, liabilities, revenues, and income. This extends the obligation beyond the entity's own ledgers to a picture of its asset and liability position.
The five-year retention. The records must be retained for a minimum of five years from the end of the relevant financial period, and the obligation persists following the liquidation, deregistration, or cessation of an entity or legal arrangement. Responsibility extends to the managers, directors, liquidators, and trustees responsible for the administration or dissolution of the person. A structure that is wound up does not extinguish the record-keeping duty; the person responsible for the dissolution carries it.
The seven-year Corporate Tax contrast. The five-year EOIR retention is shorter than the Corporate Tax record-keeping period. Article 56 of Federal Decree-Law No. 47 of 2022 requires records and documents to be kept for seven years from the end of the relevant tax period, for both taxable and exempt persons. The two periods serve different purposes: the Corporate Tax records substantiate the tax position and exemption claims; the EOIR records support information requests from foreign authorities. The prudent standard reconciles them upward. A structure that keeps to the seven-year Corporate Tax period satisfies the five-year EOIR period within it, and a single retention policy set at the longer period removes the risk of discarding a record at year five that the Corporate Tax regime still requires, or that an EOIR request reaches.
Cabinet Decision No. 209 of 2025 builds a two-tier collection machinery, with the Ministry of Finance at the centre and the regulatory authorities as the collecting arms.
The Ministry of Finance as competent authority. The Ministry of Finance is the designated central competent authority for gathering and transmitting information and for coordinating with government entities and regulatory authorities. It receives the request from the foreign competent authority, determines the information required, obtains it, and transmits it within the limits of the applicable treaty. The Ministry's authority extends to information that the requested person does not hold directly but can reasonably obtain, reflecting the foreseeable-relevance standard of the EOIR framework: a domestic inability to compel the information is not an acceptable obstacle to exchange.
The regulatory authorities as collecting arms. Regulatory authorities, including free zone authorities and licensing bodies, have an essential function. They collect, validate, and oversee compliance with information requests and furnish the information to the Ministry of Finance when required. The structure means that a free zone entity's first contact with the regime is likely to be its own free zone authority, acting on a request routed through the Ministry of Finance. The free zone authorities, long the registration and licensing counterpart for free zone businesses, become the information-collection counterpart for the exchange regime.
The powers. The Ministry of Finance and the relevant regulatory authorities may request information directly or through other government entities, verify the accuracy, completeness, and currency of the information, conduct inspections and audits where a violation is suspected, and coordinate enforcement measures across federal and local authorities. The verification power is the operational teeth: the authority does not simply receive what the person volunteers, it can test the accuracy and completeness of the records and inspect where it suspects a violation.
Confidentiality and legal professional privilege. The framework preserves confidentiality by limiting disclosure to what the applicable treaty permits and by subjecting exchange to public-order and national-security safeguards. Information subject to legal professional privilege is protected, but the protection is narrow: it covers confidential information provided to lawyers or legal representatives only where it relates to representation before courts, arbitration, mediation, judicial or administrative proceedings, or the provision of a legal opinion. The privilege does not shield ordinary accounting, ownership, or banking records held by an entity simply because they have passed through a professional adviser; it protects the advice and the representation, not the underlying records.
Cabinet Decision No. 209 of 2025 introduces, for the first time in the UAE's exchange-of-information framework, an express administrative penalty regime. Under the prior 2012 instrument, penalties were unclear or derived indirectly from other laws. The 2025 Decision sets defined fines.
The fines. The administrative penalties are:
The fines double where the violation is repeated within twelve months. They are not the most severe consequence. In addition to the fines, the regulatory authorities may suspend, decline to renew, or cancel the licence, registration, or permit, with the suspension capable of running for a period of up to six months. For a free zone entity whose entire operating basis is its licence, the licence consequence is materially more serious than the fine.
The escalation logic. The penalty structure escalates by culpability. Failure to keep or to provide records on time is the baseline at AED 20,000. Providing inaccurate information is treated more seriously at AED 60,000, because it corrupts the exchange rather than delaying it. Concealment, destruction, or manipulation is the most serious at AED 100,000, because it is active obstruction. The escalation tells a corridor structure where the regime's enforcement attention sits: not on the technical lateness of a response, but on the integrity of the records and the honesty of what is provided.
The grievance process. A person subject to an administrative penalty may submit a grievance to the relevant regulatory authority within 30 working days of receiving the penalty notice. The authority must decide the grievance within 30 working days, and a failure to respond within that period is treated as a rejection. The grievance decision is final at the administrative level, but the person may still challenge it before the court within 60 days of notification or of the expiry of the grievance response period. The route is administrative first, judicial second, with defined and short windows at each stage.
The compliance posture. The penalty regime, read with the verification and inspection powers, makes the maintenance of accurate, complete, and current records the operative compliance obligation. The fine for lateness is recoverable; the fine for inaccuracy and the licence consequence for obstruction are not the kind of exposure a corridor structure can treat as a cost of doing business. The architectural answer is a records function that holds the prescribed categories, keeps them current and accurate, and can produce them within the deadlines a request imposes.
Cabinet Decision No. 209 of 2025 governs exchange on request. It is one of two tracks in the UAE's transparency architecture, and the relationship between them is what determines a corridor structure's total exposure.
The on-request track (EOIR). Under Cabinet Decision No. 209 of 2025, a foreign competent authority asks for foreseeably relevant information, and the Ministry of Finance obtains and transmits it. The request is specific, the information is targeted, and the trigger is the foreign authority's enquiry. The obligation on the UAE person is to have the records ready and to surrender them on request.
The automatic track (AEOI). Alongside the on-request track, the UAE operates automatic exchange. The Common Reporting Standard, implemented through Ministerial Resolution No. 134 of 2021, requires UAE financial institutions to identify and report defined financial accounts to the Federal Tax Authority for onward exchange with partner jurisdictions, on a periodic basis and without any specific request. The UAE has committed to implement the updated Common Reporting Standard (CRS 2.0) with effect from 1 January 2027, expanding the standard to electronic money, central bank digital currencies, and certain crypto-asset activity, with the first exchange under CRS 2.0 to follow. The UAE has also signed the Multilateral Competent Authority Agreement on the Automatic Exchange of Information under the Crypto-Asset Reporting Framework, with implementation scheduled and first exchanges expected in 2028. The mechanics of the crypto framework, and the controlling-persons look-through that drives it, are set out in the CARF analysis.
Why both tracks matter together. The automatic track gives a foreign authority a periodic data feed: financial-account balances, and from 2027 to 2028 electronic money and crypto activity, for its residents. The on-request track lets that authority follow the data feed with a targeted request for the ownership chain, the accounting records, and the banking detail behind it. The two are designed to work in sequence: automatic exchange identifies the structure and the account; exchange on request retrieves the documentation that explains them. A corridor structure that is visible through automatic exchange is reachable through exchange on request, and the records it must hold under Cabinet Decision No. 209 of 2025 are the records the foreign authority will ask for once the automatic feed has flagged the account.
The reconciliation problem is the consequence. The information the UAE person holds under Cabinet Decision No. 209 of 2025 must reconcile with what is reported automatically under the Common Reporting Standard and the Crypto-Asset Reporting Framework, and with what the controlling persons report on their own tax returns in their jurisdictions of residence. A discrepancy between the UAE records surrendered on request, the automatic-exchange reports, and the foreign tax filings is precisely the inconsistency that an EOIR request is made to test. The records are not just a UAE compliance obligation; they are the UAE leg of a cross-border reconciliation that has to hold together.
Five patterns recur in corridor files as Cabinet Decision No. 209 of 2025 beds in after the 30 January 2026 commencement.
Trap 1: treating the free zone 0% as a transparency position. The most common error is to assume that a low UAE tax cost means a low UAE disclosure profile. Cabinet Decision No. 209 of 2025 defines "Person" and "Free Zones" independently of the Corporate Tax Law, so a Qualifying Free Zone Person at 0%, an exempt person, and a sub-threshold entity each carry the full record-keeping and disclosure obligation. The tax efficiency and the information obligation are unrelated. The architectural answer is to scope the exchange-of-information obligation against the entity's status as a UAE person, not against its Corporate Tax position, and to maintain the prescribed records regardless of the tax outcome.
Trap 2: keeping records to the five-year line and discarding at year five. The EOIR retention is a minimum of five years, but the Corporate Tax record-keeping period under Article 56 of Federal Decree-Law No. 47 of 2022 is seven years, and the obligation persists after liquidation or deregistration. A structure that sets its retention policy at the five-year EOIR minimum discards records that the Corporate Tax regime still requires and that a late EOIR request, or a request relating to an earlier period, can still reach. The architectural answer is a single retention policy set at the longer seven-year period, applied across all the prescribed categories and maintained beyond dissolution.
Trap 3: holding records offshore or with a foreign affiliate. The regime requires the information to be available and accessible, and the Ministry of Finance and regulatory authorities can inspect and verify it. A structure that stores its accounting records, ownership documentation, or banking information offshore, or relies on a foreign group affiliate to hold them, risks being unable to produce them within the deadline a request imposes, which is the failure-to-provide penalty and, on the integrity side, the kind of gap that reads as concealment. The architectural answer is to ensure the prescribed records are accessible within the UAE and producible on request, whatever the group's wider data architecture.
Trap 4: inconsistency between the UAE records and the cross-border reports. A UAE structure is visible through automatic exchange under the Common Reporting Standard and, from 2027 to 2028, the updated CRS and the Crypto-Asset Reporting Framework. An EOIR request follows the automatic feed and tests the documentation behind it. Where the ownership chain, the accounting records, or the net-asset position surrendered to the Ministry of Finance does not reconcile with the automatic-exchange reports or with the controlling persons' own tax returns, the discrepancy is the finding the request is designed to surface. The architectural answer is a single, accurate controlling-persons and ownership analysis that drives the UAE records, the automatic-exchange self-certifications, and the foreign tax filings consistently.
Trap 5: assuming professional involvement makes records privileged. The legal professional privilege carve-out is narrow: it protects confidential information provided to lawyers or legal representatives for the purpose of legal advice or representation in proceedings, not the ordinary accounting, ownership, and banking records of the entity. A structure that routes its records through an adviser and assumes they are thereby shielded from an EOIR request misreads the carve-out. The architectural answer is to treat the prescribed record categories as fully disclosable on request, and to confine the privilege expectation to genuine legal advice and representation, which is where the carve-out actually sits.
The common feature of the five traps is the assumption that a UAE structure's disclosure exposure is a function of its tax position or its adviser relationships. Under Cabinet Decision No. 209 of 2025 it is a function of the information it holds. The structure that maintains accurate, accessible, reconciled records across the prescribed categories has met the obligation; the structure that relies on its tax efficiency or its professional wrappers to keep the information quiet has misread the regime.
Cabinet Decision No. 209 of 2025 is one layer of a UAE compliance architecture that has been built out rapidly since the introduction of Corporate Tax, and it connects directly to the UK side of the corridor.
UAE Corporate Tax record-keeping. Federal Decree-Law No. 47 of 2022 requires records to be kept for seven years (Article 56), for both taxable and exempt persons, to substantiate the tax position. The EOIR records overlap heavily with the Corporate Tax records, and a single records function should serve both. The Corporate Tax position itself does not determine the EOIR obligation, but the records that support the Corporate Tax return are largely the same records an EOIR request will seek.
The eInvoicing data flow. From 1 January 2027, Phase 1 entities issue and receive invoices through the UAE eInvoicing System, transmitting tax-invoice data to the Federal Tax Authority in near real time. The eInvoicing regime creates a continuous, structured record of the entity's transactional activity that becomes part of the accounting records an EOIR request can reach. The transparency architecture and the transactional-data architecture converge: the invoice data the eInvoicing System captures is the accounting record the exchange regime can require.
The Pillar Two evidence. For in-scope multinational groups, the UAE Domestic Minimum Top-up Tax produces a GloBE Information Return and supporting substance and accounting documentation. The UAE DMTT first-filing analysis sets out the records that filing requires. Those records, and the substance evidence behind the Qualifying Free Zone Person and central-management-and-control positions, are within the accounting and ownership categories that Cabinet Decision No. 209 of 2025 covers. The Pillar Two file and the EOIR file draw on the same underlying documentation.
The UK side of the corridor. The UK reaches UAE-connected structures through its own transparency regimes: the Common Reporting Standard for financial accounts, and from 1 January 2026 the Cryptoasset Reporting Framework for crypto. A UK tax authority that identifies a UAE structure through automatic exchange can follow it with an exchange-of-information request to the UAE under the UK-UAE double taxation convention, and Cabinet Decision No. 209 of 2025 is the domestic UAE machinery that answers that request. The corridor structure is therefore reachable from the UK side through request-driven exchange, and the UAE records it must hold are the records the UK authority will ultimately receive.
The integrated reading is that the UAE has closed the gap between its tax framework and its transparency framework. The Corporate Tax record-keeping, the eInvoicing data flow, the Pillar Two documentation, the automatic-exchange reporting, and the on-request exchange under Cabinet Decision No. 209 of 2025 draw on one body of records. A corridor structure that maintains those records accurately and consistently satisfies all of them; a structure that treats each regime as a separate compliance silo holds five partial files and a reconciliation problem.
Cabinet Decision No. 209 of 2025 on Exchange of Information upon Request for Tax Purposes entered into force on 30 January 2026, thirty days after its publication in the Official Gazette. The Ministry of Finance announced the Decision on 10 February 2026. It replaces Cabinet Decision No. 17 of 2012, the prior enabling instrument, and operationalises the OECD Global Forum Exchange of Information on Request (EOIR) standard with defined record-keeping obligations, enforcement powers, and penalties.
Yes. The Decision applies to licensed natural persons, legal persons established, registered, or licensed in the UAE including free zones, legal arrangements such as trusts and joint ventures, and persons with UAE permanent establishments. The definitions of "Person" and "Free Zones" are independent of the Corporate Tax Law, so the obligations apply regardless of corporate tax liability, tax residency, or Qualifying Free Zone Person status. A free zone entity taxed at 0% on its Qualifying Income, an exempt person, and an entity below the registration threshold each carry the full record-keeping and disclosure obligation.
Persons in scope must maintain ownership and identity information including beneficial ownership and the ownership chain, banking information including account-holder details and transaction records, accounting records including invoices, contracts, correspondence, ledgers, and financial statements, and information on net assets including property, liabilities, revenues, and income. The minimum retention period is five years from the end of the relevant financial period, and it persists after liquidation or deregistration. Because the Corporate Tax record-keeping period under Article 56 of Federal Decree-Law No. 47 of 2022 is seven years, the prudent standard is a single retention policy set at the longer seven-year period.
Exchange of Information on Request under Cabinet Decision No. 209 of 2025 is request-driven: a foreign competent authority asks for foreseeably relevant information under a treaty, and the Ministry of Finance obtains and transmits it. Automatic Exchange of Information is periodic and requires no specific request: under the Common Reporting Standard (Ministerial Resolution No. 134 of 2021), UAE financial institutions report defined accounts to the Federal Tax Authority for onward exchange, and the Crypto-Asset Reporting Framework will do the same for crypto. The two work in sequence: automatic exchange identifies the account and the structure, and exchange on request retrieves the ownership, accounting, and banking documentation behind it.
The administrative penalties are AED 20,000 for failure to retain information or to provide it within the specified time, AED 60,000 for providing incorrect or inaccurate information, and AED 100,000 for concealing, destroying, or tampering with records. Penalties double for a repeat violation within twelve months. In addition, regulatory authorities may suspend, decline to renew, or cancel a licence or registration. For a free zone entity the licence consequence is frequently the more serious exposure. A person may challenge a penalty by grievance to the regulatory authority within 30 working days, with the authority deciding within 30 working days and a court challenge available within 60 days.
Only narrowly. The framework protects information subject to legal professional privilege where it is provided to lawyers or legal representatives for the purpose of legal advice or representation before courts, arbitration, mediation, or judicial or administrative proceedings. It does not protect the entity's ordinary accounting, ownership, or banking records simply because they have passed through a professional adviser. The privilege covers the advice and the representation, not the underlying records, which remain disclosable on a foreseeably relevant request.
The two regimes overlap but serve different purposes and run on different retention periods. Corporate Tax record-keeping under Article 56 of Federal Decree-Law No. 47 of 2022 requires records for seven years to substantiate the tax position and exemption claims, for both taxable and exempt persons. Cabinet Decision No. 209 of 2025 requires the prescribed information categories for at least five years to support cross-border exchange. The records overlap substantially, so a single records function should serve both, set at the longer seven-year period. The Corporate Tax position does not determine the exchange-of-information obligation; the records that support the tax return are largely the records an exchange request will seek.
A UK tax authority can identify a UAE structure through automatic exchange under the Common Reporting Standard and, from 1 January 2026, the Cryptoasset Reporting Framework, and can then make an exchange-of-information request to the UAE under the UK-UAE double taxation convention. Cabinet Decision No. 209 of 2025 is the UAE machinery that answers that request, so the UAE records of a UK-connected structure are reachable from the UK side. The practical requirement is that the UAE records reconcile with the automatic-exchange reports and with the controlling persons' UK tax filings, because the request exists to test exactly that reconciliation.
The UAE built its tax framework and its transparency framework in the same decade, and Cabinet Decision No. 209 of 2025 is the point at which the second caught up with the first. A structure's UAE tax cost and its UAE disclosure obligation are now two separate questions, and the answer to the first has never determined the answer to the second.
The UAE Domestic Minimum Top-up Tax under Cabinet Decision No. 142 of 2024 applies to financial years starting on or after 1 January 2025. First filings are due within 15 months of fiscal year-end, extended to 18 months for the transitional year. For a calendar-year MNE group, the first return is due 30 June 2027.
Read AnalysisOn 10 May 2026 the UAE Ministry of Finance moved the Phase 1 ASP appointment deadline from 31 July 2026 to 30 October 2026 by amending Ministerial Decision No. 244 of 2025. The 1 January 2027 go-live did not move. For AED 50 million+ entities the runway between ASP appointment and live filing is now nine weeks.
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