UAE Corporate Tax:​ Ministerial Decision #84 of 2025 on Audited Financial Statements

Key highlights​

• MD 84 applies to Tax Periods commencing on or after 1 January 2025. This decision also repeals MD 82 of 2023, but with MD 82 continuing to apply to Tax Periods that commenced before 1 January 2025.

• It has been clarified that the revenue threshold requirement of AED 50 million for the purpose of preparing audited financial statements applies to a Taxable Person that is not a Tax Group.

• MD 84 requires all tax groups to prepare and maintain the audited special purpose financial statements (“SPFS”). Additional guidance for the preparation of SPFS will be specified by the Authority.​

• MD 84 further clarifies that for a Non-Resident person, only Revenue derived through Permanent Establishments and/or nexuses in the State shall be taken into account for calculating the Revenue threshold of AED 50 million.

• MD 84 also requires Qualifying Free Zone Persons ("QFZPs") engaged in the activity of distribution of goods or materials in or from a Designated Zone to comply with any additional procedures prescribed by the Federal Tax Authorities.

Key takeaways and next steps​

MD 84 provides some further clarity on requirements to prepare and maintain audited financial statements specifically for tax groups and Non-Resident persons. However the specific requirements for tax groups are still to be provided.​

It is critical to monitor any additional guidance in relation to SPFS for Tax Groups and additional requirements for QFZPs engaged in distribution activities and the related impact. Taxpayers must also consider the approach they take for financial periods commencing before 1 January 2025.

It is critical for taxpayers to connect with their auditors to align on what is required. Tax Groups need to consider what data they will use to support aggregation of the group financials, and whether standalone financials statements need to be audited.

For further assistance, you can reach us at CT.UAE@pwc.com.​