CFO Advisory

When it crosses either threshold in Ministerial Decision No. 97 of 2023. A Taxable Person must maintain both files for a Tax Period if its own revenue is AED 200,000,000 or more, or if at any time in the period it is a Constituent Company of a Multinational Enterprises Group with total consolidated group revenue of AED 3,150,000,000 or more. Article 55 of Federal Decree-Law No. 47 of 2022 adds that the documentation must be submitted to the FTA within thirty days of a request. Preparing these files needs segmented management accounts, functional analysis and benchmarking, which is CFO-level work rather than bookkeeping; we scope it as soon as a client's revenue forecast approaches the threshold.

Sources: Ministry of Finance — Ministerial Decision No. 97 of 2023 Requirements for Maintaining Transfer Pricing Documentation for the Purposes of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses; Federal Tax Authority — Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses (accessed 24 October 2026)

Yes. Article 34 of Federal Decree-Law No. 47 of 2022 requires transactions and arrangements between Related Parties to meet the arm's length standard when determining Taxable Income, with no size threshold. The FTA's Transfer Pricing guide (CTGTP1) states that the rules apply not only to multinational groups but to any transactions with Related Parties or Connected Persons in domestic groups, and that exempt entities, Small Business Relief electors and standalone entities must still meet the principle even though they are not required to prepare transfer pricing documentation. In practice, intercompany management fees, loans and shared costs need a defensible pricing basis in every UAE group. We set those policies and build the management reports that evidence them.

Sources: Federal Tax Authority — Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses; Federal Tax Authority — Transfer Pricing Guide — Corporate Tax Guide CTGTP1 (October 2023) (accessed 24 October 2026)

Only if your group is very large. According to the Federal Tax Authority's October 2026 announcement of its guide on the Top-up Tax, the UAE's Qualified Domestic Minimum Top-up Tax applies to Constituent Entities located in the UAE that belong to a Multinational Enterprise Group with annual revenue of EUR 750 million or more, as shown in the ultimate parent's consolidated financial statements, in at least two of the four preceding Fiscal Years, for Fiscal Years beginning on or after 1 January 2025. Its purpose is to ensure such groups pay an effective rate of at least 15 per cent in each jurisdiction where they operate. Groups near the threshold need consolidated revenue tracking and an effective-tax-rate calculation per jurisdiction; our CFO advisory covers the registration and the modelling.

Source: Federal Tax Authority — Federal Tax Authority Issues New Guide on Scope and Registration for Top-up Tax on Multinational Enterprises (7 October 2026) (accessed 24 October 2026)

Real people, assets and spending in the free zone. Article 18 of Federal Decree-Law No. 47 of 2022 makes maintaining adequate substance in the UAE a condition of Qualifying Free Zone Person status. The FTA's Free Zone Persons guide (CTGFZP1), citing Cabinet Decision No. 100 of 2023, explains that the company must undertake its core income-generating activities in the free zone and must have adequate assets, full-time employees and an adequate amount of operating expenditure there to perform those activities. No figure is published; adequacy is judged against the activity. A CFO-level review maps headcount, premises and cost base to the qualifying activities and documents any outsourcing, which is what we deliver before the 0 per cent rate is claimed.

Sources: Federal Tax Authority — Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses; Federal Tax Authority — Free Zone Persons — Corporate Tax Guide CTGFZP1 (May 2024) (accessed 24 October 2026)

Yes, for larger borrowers. Article 30 of Federal Decree-Law No. 47 of 2022 caps deductible Net Interest Expenditure at 30 per cent of accounting EBITDA for the Tax Period, excluding exempt income. The FTA's Determination of Taxable Income guide (CTGDTI1), citing Ministerial Decision No. 126 of 2023, confirms a de minimis threshold: if Net Interest Expenditure is below AED 12 million the rule does not apply, and above it the deductible amount is the greater of AED 12 million and 30 per cent of adjusted EBITDA. Disallowed interest can be carried forward for ten Tax Periods. Debt-funded growth, shareholder loans and acquisition finance therefore need modelling against EBITDA, which is part of our treasury and banking advisory.

Sources: Federal Tax Authority — Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses; Federal Tax Authority — Determination of Taxable Income — Corporate Tax Guide CTGDTI1 (July 2024) (accessed 24 October 2026)

Tight common ownership and aligned accounting. Under Article 40 of Federal Decree-Law No. 47 of 2022, the Parent Company must own at least 95 per cent of the Subsidiary's share capital, voting rights and entitlement to profits and net assets; both must have the same Financial Year and prepare their financial statements using the same accounting standards; and neither may be an Exempt Person or a Qualifying Free Zone Person. The FTA's Tax Groups guide (CTGTGR1) confirms that a Tax Group files only one Tax Return and prepares consolidated financial statements for that purpose, which under Ministerial Decision No. 84 of 2025 must now be audited. We model the cash-tax, loss-utilisation and compliance effects before a group elects.

Sources: Federal Tax Authority — Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses; Federal Tax Authority — Tax Groups — Corporate Tax Guide CTGTGR1 (January 2024) (accessed 24 October 2026)

Indefinitely, but with two limits. Article 37 of Federal Decree-Law No. 47 of 2022 allows a Tax Loss to be offset against the Taxable Income of subsequent Tax Periods, but the amount used in any one period cannot exceed 75 per cent of that period's Taxable Income unless the Cabinet sets another percentage; the balance carries forward. Article 39 then conditions carry-forward on continuity: the same persons must have continuously held at least a 50 per cent ownership interest from the start of the loss period to the end of the period in which the loss is used, or, after a larger ownership change, the company must have continued the same or a similar business. Loss forecasting therefore belongs in every funding and exit model we build.

Source: Federal Tax Authority — Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses (accessed 24 October 2026)

The directors or shareholders, whoever keeps the books. Under Regulation 76 of the RAK Economic Zone Authority Companies Regulations 2023, the shareholders or directors must cause accounts to be prepared for each financial year, approve them and sign them on the company's behalf. In ADGM, section 447 of the Companies Regulations 2020 requires directors who rely on an audit exemption to state on the balance sheet that they acknowledge their responsibilities for the accounting records and the preparation of accounts. Outsourcing the finance function does not transfer that duty. An outsourced CFO's job is to give the board a reporting pack it can sign with confidence; we build those packs and present them at board level.

Sources: RAK Economic Zone Authority — RAK Economic Zone Authority Companies Regulations of 2023; Abu Dhabi Global Market — Companies Regulations 2020 (Consolidated Version) (accessed 24 October 2026)