# Federal Tax Authority Decision No. 5 of 2025 on Determining the Tax Compliance Requirements for Unincorporated Partnerships, Foreign Partnerships and Family Foundations - Source page: https://solvefortax.com/legislation/312 - Topic: Corporate Tax - Type: Federal Tax Authority Decision - Status: Active - Chapter: VI. Anti-Abuse and Compliance Measures - Issued: May 19, 2025 - Effective: 1 July 2025 - Official PDF: https://solvefortax.com/api/pdfs/Federal-Tax-Authority-Decision-No-5-of-2025-for-Publishing.pdf - Publisher: Solve for Tax, UAE Tax Law Library (https://solvefortax.com/) ## Summary This Federal Tax Authority Decision establishes comprehensive tax compliance requirements for Unincorporated Partnerships, Foreign Partnerships, and Family Foundations under the UAE Corporate Tax Law. The Decision mandates that partners in an Unincorporated Partnership must appoint an authorised partner to handle all Corporate Tax registration and compliance matters on behalf of all partners. It prescribes detailed timelines for registration, with partnerships whose first Financial Year ended before the effective date required to register by 31 August 2025, and others within three months from the end of their first Financial Year. The authorised partner must submit annual declarations within nine months of the Financial Year end, with a special deadline of 31 December 2025 for Financial Years ending on or before 31 March 2025. The Decision addresses the determination of distributive shares among partners, specifying that where shares cannot be identified, assets, liabilities, income and expenditure shall be allocated equally among all partners. It establishes procedures for Tax Deregistration within three months of cessation of business activity. The legislation provides for applications by Unincorporated Partnerships to be treated as Taxable Persons in their own right, with applications required before the end of the relevant Financial Year, though exceptions allow applications made by 31 December 2025 to be effective from earlier Tax Periods. For Foreign Partnerships treated as Unincorporated Partnerships, the Decision requires partners to submit annual declarations when filing their own Tax Returns. Family Foundations or juridical persons wholly owned by Family Foundations may apply to be treated as Unincorporated Partnerships, with similar timing requirements and exceptions for applications made by 31 December 2025. Such entities must submit annual confirmations within nine months of the Tax Period end to verify ongoing compliance with conditions. This Decision repeals Federal Tax Authority Decision No. 16 of 2023 and came into effect on 1 July 2025. ## Key points • Effective date: 1 July 2025 • Issued: 19 May 2025 • Partners in an Unincorporated Partnership not treated as a Taxable Person must appoint one authorised partner to act on behalf of all partners for Corporate Tax registration purposes (Article 2, Clause 1) • Unincorporated Partnerships whose first Financial Year ended before 1 July 2025 must submit Tax Registration application on or before 31 August 2025 (Article 2, Clause 2a) • Unincorporated Partnerships whose first Financial Year did not end before 1 July 2025 must submit Tax Registration application within three (3) months from the end of the first Financial Year (Article 2, Clause 2b) • Authorised partner must submit annual declaration within nine (9) months from the end of the relevant Financial Year (Article 3, Clause 1) • Financial Year of an Unincorporated Partnership is the Gregorian calendar year or twelve (12) month period for which financial statements are prepared (Article 3, Clause 1a) • For any Financial Year ending on or before 31 March 2025, the deadline to file annual declaration is 31 December 2025 (Article 3, Clause 2) • Where distributive shares of partners cannot be identified, assets, liabilities, income and expenditure shall be allocated equally to each partner (Article 4) • Tax Deregistration application must be filed within three (3) months from the date of cessation of Business or Business Activity (Article 5) • Application for Unincorporated Partnership to be treated as Taxable Person must be made before the end of the relevant Financial Year (Article 6, Clause 1) • Applications made on or before 31 December 2025 may be approved effective from the commencement of any Tax Period ending on or before 31 December 2025 (Article 6, Clause 2) • For Unincorporated Partnerships that are Taxable Persons, deadline to file Tax Return is 31 December 2025 for any Tax Period ending on or before 31 March 2025 (Article 7, Clause 1) • For Unincorporated Partnerships that are Taxable Persons, deadline to settle Corporate Tax Payable is 31 December 2025 for any Tax Period ending on or before 31 March 2025 (Article 7, Clause 2) • Partner in a Foreign Partnership treated as Unincorporated Partnership must submit annual declaration on behalf of the Foreign Partnership when filing their own Tax Return per Article 53 of Corporate Tax Law (Article 8) • Family Foundation or juridical person wholly owned by Family Foundation must apply before the end of the relevant Tax Period to be treated as Unincorporated Partnership (Article 9, Clause 1) • Family Foundation applications made on or before 31 December 2025 may be approved effective from commencement of any Tax Period ending on or before 31 December 2025 (Article 9, Clause 2) • Family Foundations approved as Unincorporated Partnerships must submit annual confirmation within nine (9) months from end of relevant Tax Period (Article 10, Clause 1) • For Family Foundations, deadline to file annual confirmation is 31 December 2025 for any Tax Period ending on or before 31 March 2025 (Article 10, Clause 2) • References Article 51 Clause 2, Article 53 Clause 6 and Clause 1, Article 16 Clause 3 and Clause 8, Article 52 Clause 1, Article 48, and Article 17 Clause 2 and Clause 3 of Federal Decree-Law No. 47 of 2022 (Corporate Tax Law) • References Clause 3 of Article 4 of Ministerial Decision No. 261 of 2024 • Approved by the Board of Directors of the Federal Tax Authority at its 38th meeting held on 29 April 2025 • Repeals Federal Tax Authority Decision No. 16 of 2023 (Article 11) ## This document relies on - [Federal Decree-Law No. 47 of 2022 on Taxation of Corporations and Businesses](https://solvefortax.com/legislation/18) (implements) - [Federal Decree-Law No. 28 of 2022 on Tax Procedures](https://solvefortax.com/legislation/72) (issued under) - [Cabinet Decision No. 74 of 2023 on Executive Regulation of Federal Decree-Law No. 28 of 2022 on Tax Procedures](https://solvefortax.com/legislation/147) (refers to) - [Ministerial Decision No. 261 of 2024 on Unincorporated Partnership, Foreign Partnership and Family Foundation ](https://solvefortax.com/legislation/20) (implements) - [FTA Decision No. 16 of 2023 on Determining the Requirements for the Registration of the Unincorporated Partnership and Determining the Distributive Shares of Partners in an Unincorporated Partnership](https://solvefortax.com/legislation/27) (replaces) ## Full text # Determining the Tax Compliance Requirements for Unincorporated Partnerships, Foreign Partnerships and Family Foundations for the purposes of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses and its amendments This is not an official translation: Federal Tax Authority Decision No. 5 of 2025 – Issued 19 May 2025 – (Effective 1 July 2025) ## The Chairman of the Board of Directors of the Federal Tax Authority has decided: - Having reviewed the Constitution, - Federal Decree-Law No. 13 of 2016 on the Establishment of the Federal Tax Authority, and its amendments, - Federal Decree-Law No. 28 of 2022 on Tax Procedures, and its amendments, - Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses, and its amendments, - Cabinet Decision No. 74 of 2023 on the Executive Regulation of Federal Decree-Law No. 28 of 2022 on Tax Procedures, - Decision of the Chairman of the Board of Directors No. 9 of 2021 on the Delegation to the Vice Chairman of the Board of Directors of the Federal Tax Authority, - Ministerial Decision No. 261 of 2024 on Unincorporated Partnership, Foreign Partnership and Family Foundation for the Purposes of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses, - FTA Decision No. 16 of 2023 on Determining the Requirements for the Registration of the Unincorporated Partnership and Determining the Distributive Shares of Partners in an Unincorporated Partnership for the purposes of Federal Decree Law No. 47 of 2022 on the Taxation of Corporations and Businesses, and its amendments, and - Pursuant to the approval of the Board of Directors of the Federal Tax Authority on amending the Policy for Determining the Requirements for the Registration of the Unincorporated Partnership and Determining the Distributive Shares of Partners in an Unincorporated Partnership at its 38th meeting held on 29 April 2025. ## Article 1 – Definitions Words and expressions in this Decision shall have the same meanings specified in the Federal-Decree Law No. 47 of 2022 referred to above (“Corporate Tax Law”), unless the context otherwise requires. ## Article 2 – Requirements for the Registration of the Unincorporated Partnership 1. For the purposes of Clause 2 of Article 51 of the Corporate Tax Law, the partners in an Unincorporated Partnership that is not treated as a Taxable Person in its own right must appoint one of the partners to be the authorised partner to act on behalf of all the partners in relation to registration for Corporate Tax purposes. 2. The authorised partner shall be required to submit an application to the Authority to register the Unincorporated Partnership for purposes of Corporate Tax according to the forms specified by the Authority in order to obtain a Tax Registration Number, in accordance with the following: a. For an Unincorporated Partnership whose first Financial Year ended prior to the effective date of this Decision, such Unincorporated Partnership shall submit the Tax Registration application on or before 31 August 2025. b. For an Unincorporated Partnership whose first Financial Year did not end prior to the effective date of this Decision, such Unincorporated Partnership shall submit the Tax Registration application within a period not exceeding (3) three months from the end of the first Financial Year of the Unincorporated Partnership. ## Article 3 – The Annual Declaration of the Unincorporated Partnership 1. For the purposes of Clause 6 of Article 53 of the Corporate Tax Law, the authorised partner of an Unincorporated Partnership that is not treated as a Taxable Person in its own right is required to submit an annual declaration on behalf of all the partners in the Unincorporated Partnership within a period not exceeding (9) nine months from the end of the relevant Financial Year of the Unincorporated Partnership or part thereof, taking the following into account: a. The Financial Year of an Unincorporated Partnership shall be the Gregorian calendar year or the (12) twelve-month period for which the Unincorporated Partnership prepares financial statements. b. The annual declaration shall include all the information necessary to determine the Taxable Income of the partners in the Unincorporated Partnership during the relevant Financial Year. 2. Notwithstanding Clause 1 of this Article, for any Financial Year that ended on or before 31 March 2025, the deadline to file the annual declaration shall be 31 December 2025. ## Article 4 – Determining the Distributive Shares of Partners in the Unincorporated Partnership For the purposes of Clause 3 of Article 16 of the Corporate Tax Law, where the distributive share of the partners cannot be identified, the assets, liabilities, income and expenditure of the Unincorporated Partnership shall be allocated equally to each partner in the Unincorporated Partnership. ## Article 5 – Timeline to Apply for Tax Deregistration For the purposes of Clause 1 of Article 52 of the Corporate Tax Law, the authorised partner of an Unincorporated Partnership that is not a Taxable Person shall file a Tax Deregistration application within a period not exceeding (3) three months from the date of cessation of the Business or Business Activity, whether such cessation was due to dissolution or termination of the Unincorporated Partnership or due to any other reason. ## Article 6 – Application for an Unincorporated Partnership to be a Taxable Person 1. For the purposes of Clause 8 of Article 16 of the Corporate Tax Law, where the partners in an Unincorporated Partnership submit an application, they must make it before the end of the relevant Financial Year of the Unincorporated Partnership. If the Authority approves the application, the Unincorporated Partnership shall be treated as a Taxable Person effective from the commencement of the Tax Period in which the application is made, or from the commencement of the next Tax Period as specified in the application. 2. As an exception to the provisions of Clause 1 of this Article, where an application is made by the partners in an Unincorporated Partnership on or before 31 December 2025, the Authority may approve to treat the Unincorporated Partnership as a Taxable Person effective from the commencement of any Tax Period ending on or before 31 December 2025 as specified in the application. ## Article 7 – Deadlines to File the Tax Return and Settle the Corporate Tax Payable for an Unincorporated Partnership that is a Taxable Person 1. For the purposes of Clause 1 of Article 53 of the Corporate Tax Law, the deadline to file the Tax Return to the Authority by an Unincorporated Partnership that is a Taxable Person in its own right shall be 31 December 2025 for any Tax Period that ended on or before 31 March 2025. 2. For the purposes of Article 48 of the Corporate Tax Law, the deadline to settle the Corporate Tax Payable by an Unincorporated Partnership that is a Taxable Person in its own right shall be 31 December 2025 for any Tax Period that ended on or before 31 March 2025. ## Article 8 – A Foreign Partnership that is treated as an Unincorporated Partnership For the purposes of Clause 3 of Article 4 of Ministerial Decision No. 261 of 2024, a Taxable Person that is a partner in a Foreign Partnership is required to submit an annual declaration on behalf of the Foreign Partnership when filing the Tax Return of that partner as per Article 53 of the Corporate Tax Law. ## Article 9 – Submitting an Application for a Family Foundation to be treated as an Unincorporated Partnership 1. For the purposes of Clause 2 of Article 17 of the Corporate Tax Law, a Family Foundation or a juridical person wholly owned and controlled by a Family Foundation must make an application before the end of the relevant Tax Period. If the application is approved, the Family Foundation or the juridical person wholly owned and controlled by a Family Foundation shall be treated as an Unincorporated Partnership effective from the commencement of the Tax Period in which the application is made, or from the commencement of the next Tax Period as specified in the approval of the Application. 2. As an exception to the provisions of Clause 1 of this Article, where an application is made by a Family Foundation or a juridical person wholly owned and controlled by a Family Foundation on or before 31 December 2025, the Authority may approve to treat the Family Foundation as an Unincorporated Partnership effective from the commencement of any Tax Period ending on or before 31 December 2025 as specified in the application. ## Article 10 – The Annual Confirmation of a Family Foundation 1. For the purposes of Clause 3 of Article 17 of the Corporate Tax Law, a Family Foundation or a juridical person that is wholly owned and controlled by a Family Foundation, that has had an application under Clause 1 of Article 17 of the Corporate Tax Law approved, is required, within a period not exceeding (9) nine months from the end of the relevant Tax Period, to submit an annual confirmation that the conditions stipulated in Clause 1 of Article 17 of the Corporate Tax Law have been met for the relevant Tax Period. 2. As an exception to the provisions of Clause 1 of this Article, the deadline to file the annual confirmation shall be 31 December 2025 for any Tax Period that ended on or before 31 March 2025. ## Article 11 – Repeals Federal Tax Authority Decision No. 16 of 2023 referred to above as well as any text or provision contrary to or inconsistent with the provisions of this Decision shall be repealed. ## Article 12 – Implementation of the Decision This Decision shall be published in the Official Gazette and shall come into effect from 1 July 2025.