UAE Federal Tax Authority (“FTA”) Issues Public Clarifications on Corporate Tax Treatment of Family Wealth Management Structures.
On 19.09.2025, the UAE’s FTA released a public clarification (CTP008) regarding the corporate tax treatment of family wealth structures. This clarification helps in determining whether family foundations and related entities may be treated as tax transparent for the purposes of Federal Decree Law No. 47 of 2022.
Key Takeaways
- Foundations established under the DIFC/ADGM foundation laws or a mainland trust with separate legal personality constitutes as a taxable person and can apply to the FTA under Article 17 to be treated as tax-transparent.
- Where the entity does not have a separate legal personality (e.g. trusts in DIFC/ADGM) are by default treated as tax transparent, without having to apply for Family Foundation status.
- Holding vehicles / SPVs wholly owned by a tax-transparent family foundation may themselves apply for transparency, even across multiple layers.
- Single Family Offices (SFOs) and Multi Family Offices (MFOs) are generally considered taxable persons and subject to corporate tax.
- Family members are not subject to corporate tax on personal investment or real estate income.
- If conditions are breached, transparency is lost retroactively, and the structure becomes a taxable person from the start of the tax period.
ADGM’s Financial Services Regulatory Authority (“FSRA”) Proposes New Regulatory Framework for Fiat-Referenced Tokens.
The ADGM’s FSRA published Consultation Paper No. 9 of 2025 on 09.09.2025 proposing a comprehensive regulatory framework to govern activities involving Fiat-Referenced Tokens (“FRTs”) – a class of stablecoins pegged to fiat currencies – and seeks stakeholder feedback through 07.10.2025.
Key Takeaways
- ADGM issued FRTs will be automatically accepted. Foreign FRTs must meet criteria on reserves.
- Issuers must meet minimum capital and prudential requirements, maintain well-defined reserve assets, and follow risk controls to ensure redeemability.
- Issuers are required to publish a white paper with full disclosures (redemption mechanism, reserve structure, risks) and provide ongoing attestation and audit reports.
- The consultation period will close on 07.10.2025; firms operating in crypto, payments or token issuance are advised to review how the proposals may affect their operations.
UAE Sets New Income Thresholds for Visit Visa Sponsorship
The UAE’s Federal Authority for Identity and Citizenship, Customs and Port Security (ICP) outlined income requirements for UAE residents who want to sponsor their family members and friends.
Key Takeaways
- There are four new categories of visit visa:
- AI Specialist Visa issued for single or multiple entries for technology and AI professionals;
- Entertainment Visa granted to foreigners visiting temporarily for leisure purposes;
- Event Visa for participants in festivals, conferences, exhibitions, seminars or cultural, economic, sports, religious, or educational activities;
- Cruise Ship and Leisure Boat Visa, a multiple-entry visa for tourists arriving on cruise ships or leisure boats.
- Each new visa requires sponsorship or hosting by an authorised entity like a technology company for AI Specialist Visa, entertainment organiser for Entertainment Visa, public or private sector entity for event visa and a licensed cruise or leisure operator for Cruise Ship and Leisure Boat Visa.
- The new income-based requirements for residents wishing to sponsor family or friends on a visit visa has also been introduced:
- First-degree relatives (father, mother, spouse, son or daughter): AED 4000 per month;
- Second-degree relatives (siblings, grandparents, grandchildren): AED 8000 per month;
- Third-degree relatives (uncles, aunts, cousins): AED 8000 per month; and
- Friends (non-relatives): AED 15,000 per month.
- Business Exploration Visa now requires financial solvency to establish a company, ownership of a share in an existing company outside the country or proven professional practice.
- Humanitarian Residence Permit can be issued for 1 year, with a possibility of renewal, designed to support individuals from countries affected by conflict or natural disasters or widows, divorced women to obtain residence without a sponsor.
- The UAE has also standardized visa durations and extension procedures. There are now six types of permitted stays, each with specified conditions for extension.
- These reforms support the UAE’s Vision 2031, using immigration policy as a tool to attract talent, boost sectoral growth, enhance tourism, and streamline administrative processes.
UAE Ministry of Finance (“MoF”) Introduces New Rules and Deadlines for Businesses on using Digital Invoices.
The UAE’s MoF on 29.09.2025, issued Ministerial Decisions 243 and 24 of 2025 on the Electronic Invoicing System, setting out the legal framework, scope, and implementation phases for e-invoicing.
Key Takeaways:
- E-invoicing shall apply to all businesses conducting commercial transactions in the UAE including those involving non-residents.
- Implementation Timeline is as follows:
- Pilot phase from 01.07.2026
- Businesses with revenues of AED 50 Million by 01.01.2027
- Businesses with revenues below AED 50 Million by 01.07.2027
- Government entities must comply by 01.10.2027
- All businesses must appoint an Accredited Service Provider (“ASP”) by the specified deadlines to facilitate the e-invoicing system implementation. The list of ASPs shall be published by the MoF.
- E-Invoices and E-Credit Notes must be issued and transmitted by the Issuer through the Electronic Invoicing System within 14 days from the Date of Business Transaction.
- Any Person subject to the Electronic Invoicing System shall store all Electronic Invoices, Electronic Credit Notes, and any associated data within the State in accordance with the timeline prescribed under the Tax Procedures Law.
- Businesses operating in the UAE should prepare and review their current invoicing practices for compliance with the upcoming e-invoicing requirements. This includes appointing ASPs, implementing necessary changes to invoicing processes and ensuring that data storage complies with UAE regulations.
- This Decision shall be published in the Official Gazette and shall come into force on the date of its publication.
