On 22 December 2025, the UAE Ministry of Finance issued Ministerial Decision No. 336 of 2025, designating the Dubai Virtual Assets Regulatory Authority as a “Competent Authority” for defined purposes under the UAE Corporate Tax framework.
The Decision was issued was issued pursuant to Ministerial Decision No. 229 of 2025 concerning Qualifying Activities and Excluded Activities for the purposes of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses.
Essentially, the designation is limited in scope. Accordingly, Article (1) of this Decision provides that VARA is recognised as a Competent Authority solely for the Qualifying Activities of:
- Wealth and Investment Management Services; and
- Fund Management Services,
as defined in Ministerial Decision No. 229 of 2025.
This clarification narrows the application of the Decision. The designation does not extend to all virtual asset activities but specifically to those qualifying activities falling within the above categories and within VARA’s regulatory remit under Dubai Law No. (4) of 2022 Regulating Virtual Assets in the Emirate of Dubai.
Further, pursuant to Article (2), the Decision is effective from 1 June 2023, notwithstanding its issuance date. This retroactive application is particularly significant for businesses assessing prior tax periods under the Corporate Tax regime.
Practical Implications for Businesses
Businesses operating in the virtual assets and digital asset management space should consider the following:
- Whether their licensed activities fall within “Wealth and Investment Management Services” or “Fund Management Services” as defined under Ministerial Decision No. 229 of 2025;
- Whether regulatory confirmation or certification from VARA is required to substantiate qualification under the Corporate Tax framework;
- The potential impact on their classification as conducting Qualifying Activities; and
- The corresponding effect on their Corporate Tax treatment and compliance position.
Given the technical interplay between licensing classification and Corporate Tax eligibility, an early regulatory and tax alignment review is advisable.