Ministerial Decision
No. 84 of 2025
In Force
Ministerial Decision No. 84 of 2025 on Audited Financial Statements
What changed from MD 82/2023
- Art. 2 — Expanded from 2 to 4 clauses: Tax Groups now excluded from AED 50M threshold; new requirement for Tax Groups to prepare special purpose financial statements; new QFZP distributor compliance clause; Non-Resident Persons assessed only on UAE PE/nexus revenue
- Art. 1 (Definitions) — minor wording only
Preamble
Minister of State for Financial Affairs:
- Having reviewed the Constitution,
- Federal Law No. 1 of 1972 on the Competencies of Ministries and Powers of the Ministers, and its amendments,
- Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses, and its amendments,
- Ministerial Decision No. 82 of 2023 on the Determination of Categories of Taxable Persons Required to Prepare and Maintain Audited Financial Statements for the Purposes of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses,
- Ministerial Decision No. 114 of 2023 on the Accounting Standards and Methods for the Purposes of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses,
- Ministerial Decision No. 265 of 2023 Regarding Qualifying Activities and Excluded Activities for the Purposes of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses,
Has decided:
Article 1 — Definitions #sec-1
Words and expressions in this Decision shall have the meanings specified in the Federal Decree-Law No. 47 of 2022 referred to above ("Corporate Tax Law"), unless the context otherwise requires.
Article 2 — Preparing and Maintaining Audited Financial Statements #sec-2
AmendedExpanded from 2 to 4 clauses; Tax Group and Non-Resident rules added
- For the purposes of Clause (2) of Article (54) of the Corporate Tax Law, all of the following shall prepare and maintain audited financial statements:
- A Taxable Person that is not a Tax Group and that derives Revenue exceeding AED 50,000,000 (fifty million United Arab Emirates dirhams) during the relevant Tax Period.
- A Qualifying Free Zone Person.
- For the purposes of Clause (2) of Article (54) of the Corporate Tax Law and Article (3) of Ministerial Decision No. 114 of 2023 referred to above, a Tax Group shall prepare and maintain audited special purpose financial statements in accordance with the form, procedures and rules specified by the Authority.
- Without prejudice to Clause (1) of this Article, a Qualifying Free Zone Person engaged in the activity of distribution of goods or materials in or from a Designated Zone in accordance with Ministerial Decision No. 265 of 2023 referred to above shall comply with any additional procedures prescribed by the Authority.
- For the purposes of calculating the Revenue threshold specified in Clause (1) of this Article for a Non-Resident Person, only Revenue derived through Permanent Establishments and/or nexuses in the State shall be taken into account.
Article 3 — Repeals #sec-3
Ministerial Decision No. 82 of 2023 referred to above shall be repealed but it shall continue to apply to Tax Periods that commenced before 1 January 2025.
Article 4 — Application of the Decision to Tax Periods #sec-4
This Decision shall apply to Tax Periods commencing on or after 1 January 2025.
Article 5 — Publication and Application of the Decision #sec-5
This Decision shall be published and shall come into effect on the date of its issuance.