Issue

The Federal Decree-Law No. 47 of 2022 on the
Taxation of Corporations and Business, and its
amendments (“Corporate Tax Law”) applies to Tax
Periods commencing on or after 1 June 2023.

A Real Estate Investment Trust (“REIT”) that
meets all of the conditions of Article 10(1) of the
Corporate Tax Law1 and Article 4(1) of Cabinet
Decision No. 34 of 2025 on Qualifying Investment
Funds and Qualifying Limited Partnerships for the
Purposes of Federal Decree-Law No. 47 of 2022 on
the Taxation of Corporations and Businesses
(“Cabinet Decision No. 34 of 2025”)
2
can make an
application to the FTA to be exempt from
Corporate Tax as a Qualifying Investment Fund,
effective from the beginning of the Tax Period
specified in the application or any other date
determined by the FTA.3

For clarity, this clarification refers to a REIT that is,
or will be, exempt from Corporate Tax as a
Qualifying Investment Fund.

For Tax Periods commencing on or after 1 January
2025, where a REIT is exempt from Corporate Tax,
Resident and Non-Resident juridical persons that
are investors in the REIT are subject to Corporate
Tax on 80% of the prorated Immovable Property
Income of the REIT.4 However, if the REIT makes a
distribution within 9 months from the end of its
Financial Year and the investor did not receive the
dividend distribution due to disposal of its entire
Ownership Interest in the REIT, the investor will
not be subject to Corporate Tax on the Immovable
Property Income of the REIT (as explained
below).5