Polaris Briefing: Week 39 — the last five days before the corporate-tax deadline, ADGM moves first on funds, and the Ministry of Finance goes retail again

This is the first numbered edition of a series we intend to publish every Saturday: the week as it looked from a firm that forms companies, keeps them compliant and puts them in front of banks across the UAE, Georgia, Cyprus and Switzerland. The selection is ours; the facts are the regulators’. Where a rule, a date or a figure appears below it is taken from the issuing authority and linked at the end. Where we describe market sentiment we say so and name the press source, because sentiment is not a fact and should not be filed as one.

01The corporate-tax cliff on 30 SeptemberDeadline

What happened: the Federal Tax Authority spent September reminding every taxable person whose financial year ended on 31 December 2025 that the corporate-tax return must be filed and the tax paid no later than 30 September 2026 — nine months after year-end — and that exempt persons required to register must lodge their annual declarations within the same nine-month window. The Authority was explicit that the obligation extends to businesses electing Small Business Relief, which must still register, file a simplified return and keep the records that let the FTA verify revenue, taxable income and eligibility. Filing, payment and registration run around the clock on EmaraTax, directly or through an approved tax agent. The FTA’s announcements page carries a second date for the same week: 28 September is the final deadline for VAT returns due this month.

Why it matters: this is the second corporate-tax filing season for calendar-year companies and the first in which the Authority’s risk-based audit programme is fully operational. A late return and a late payment are separate penalty events, the records obligation is enforceable on its own, and a company that believes it owes nothing — a holding company with dividend income, a free-zone entity claiming the qualifying regime, a dormant vehicle — still has to file. The mistake we see most often is a DIFC or RAK ICC holding treating a nil liability as a nil obligation.

02ADGM finalises its funds framework while the DIFC is still consultingRegulation

What happened: on 16 September the Financial Services Regulatory Authority in ADGM published the finalised enhancements to its framework for funds and fund managers, closing the consultation it opened in 2025. In Dubai, the DFSA’s Consultation Paper 173 of July 2026 proposes an overhaul of the DIFC collective-investment regime, including the removal of specialist fund categories and the external fund manager regime; comments closed on 7 September and the final rules have not yet been published. The same ADGM week brought EQT’s decision to open an Abu Dhabi office for its Middle East platform on 23 September, iCapital’s ADGM licence with a Sharia-compliant alternatives strategy, and a Registration Authority consultation on regulations for undeveloped commercial land.

Why it matters: the two financial free zones are running parallel reforms of the same product, and for the first time in years one of them has finished before the other. For a family office or a promoter deciding this quarter where to domicile a fund or a fund manager, the ADGM rules are now knowable and the DIFC rules are not. That is a timing consideration, not a quality judgment; the DIFC’s proposals are, on their face, a welcome simplification. But a structure has to be built on rules that exist.

03The Ministry of Finance goes retail again: 5.06% for five yearsMarkets

What happened: the Ministry of Finance opened subscriptions for the second issuance under its Sovereign Retail T-Sukuk Programme on 23 September, closing at 14:00 on 28 September, with a five-year tenor, an annual profit rate of 5.06 per cent paid semi-annually, a target size of AED 50 million and a minimum subscription of AED 1,000. Allocation is scheduled for 29 September, issuance and refunds of excess subscriptions on 30 September, and listing on Nasdaq Dubai on 1 October. The inaugural two-year issuance in June carried a 4.30 per cent profit rate and was listed on Nasdaq Dubai on 2 July.

Why it matters: a sovereign, Shariah-compliant, dirham-denominated instrument that a resident can buy from a phone for AED 1,000 is a small thing in market terms and a large thing in ecosystem terms. It gives conservative clients a benchmark against which a bank’s deposit offer can be measured, it deepens the domestic yield curve the Central Bank’s own rulebook leans on, and it tells us where the state thinks five-year dirham risk should price.

04The Central Bank’s resilience regime is now the banks’ problem, and therefore yoursBanking

What happened: the Central Bank’s Operational Risk Management Regulation, C 1/2026, came into force on 14 September, replacing the 2018 standards. It applies to all licensed financial institutions with legal personality, not only banks, and moves the supervisory question from whether controls exist to whether critical operations can continue, recover and adapt through disruption — technology failures, cyberattacks, fraud and third-party dependencies included. Press reporting of the regulation describes short incident-reporting windows and mandatory testing; the binding text is the one in the Central Bank’s rulebook.

Why it matters: everything a bank must now evidence about its own resilience flows downstream into what it asks of its customers and vendors. Longer onboarding questionnaires, more questions about payment-service providers a company uses, more scrutiny of payroll and treasury platforms, and, as we described in this week’s Wage Protection System guide, a WPS pipeline that now runs on upgraded, more tightly monitored rails. Companies that treat their bank as a utility will find the utility asking for their business-continuity plan.

05Dubai property: the market that has stopped forgiving non-deliverySentiment

What happened: this is the one item in the edition that rests on market reporting rather than a regulator’s text, and we flag it as such. Trade coverage of the International Property Show in Dubai reported industry consensus that there is no room left for developers who cannot deliver and that new launches are drying up; separately, weekly press roundups reported falling Dubai rents alongside a year of record hand-overs. None of these is an official statistic and none should be quoted as one.

Why it matters: for a client whose DIFC or RAK ICC foundation holds off-plan units, a market that rewards completion over launch changes the risk in the portfolio from price to counterparty. The questions to ask a developer this autumn are about escrow, construction milestones and Oqood registration, not about the launch price of the next tower.

06Oman opens its zones: OPAZ Resolution 81/2026Region

What happened: the Public Authority for Special Economic Zones and Free Zones issued the executive regulations of Oman’s Special Economic Zones and Free Zones Law under Resolution 81/2026, implementing Royal Decree 38/2025. According to the authority’s announcement as reported, the regulations cover the full investment cycle — land and property allocation, licensing, incentives and exemptions, compliance and real-estate development — and set out rules for foreign property ownership and investor residency within the zones. Earlier in the year Oman removed the local-sponsor requirement for residency applications by foreign property owners.

Why it matters: Oman is building a coherent, single-regulator zone regime with residency attached, and for a price-sensitive client comparing RAKEZ, Meydan or a northern-emirates zone with a Duqm or Sohar licence, it is now a real alternative for manufacturing, logistics and hospitality projects. It is not a substitute for the UAE’s banking depth or its financial free zones.

07Georgia: a week of central-bank diplomacy in TbilisiCorridor

What happened: the National Bank of Georgia hosted a regional central-bank governors’ roundtable in Tbilisi in cooperation with J.P. Morgan on 18 September, followed by a run of bilateral meetings — the governors of the central banks of Armenia and of Bosnia and Herzegovina, the deputy governor of the People’s Bank of China and, on 23 September, a memorandum of understanding with the central bank of Hungary. The Swift Payments Forum for the Caucasus and Turkey was held in Tbilisi on 17 September with the National Bank’s support, and the Bank’s vice-governors represented Georgia at the Global Fintech Fest and the International Public Asset Management Forum in the same week.

Why it matters: for the clients we take along the Dubai–Tbilisi corridor, the relevant fact is the direction of travel: a central bank that is building correspondent relationships, payment-system links and supervisory ties outward rather than inward. That is what keeps Georgian banks connected to the dollar and euro clearing that a trading company depends on.

08The diary for Week 40Week ahead