The Ministry of Finance of the United Arab Emirates has published Cabinet Decision No. 34 of 2025, replacing the earlier Cabinet Decision No. 81 of 2023, significantly amending the conditions to benefit from the tax exemption regime for Qualifying Investment Funds and Qualifying Limited Partnerships under Federal Decree-Law No. 47 of 2022 on the taxation of corporations and businesses.
The new Cabinet Decision aims to further position the Emirates as a leading investment hub by removing restrictive requirements and introducing a more flexible exemption regime for fund structures, while also ensuring adequate reporting and transparency at the investor level.
Although Cabinet Decision No. 81 of 2023 continues to apply to Tax Periods beginning before 1 January 2025, new Cabinet Decision No. 34 of 2025 will apply to all Tax Periods commencing on or after that date.
In this article, our Tax Partner, Olivier Remacle and our Tax Principal, Barbara Schwartz, describe the amendments provided by the new Cabinet Decision to the UAE Fund tax exemption rules.