On 10 February 2026, the UAE Ministry of Finance announced the issuance of Cabinet Decision No. 209 of 2025on the Exchange of Information Upon Request for Tax Purposes (the “Decision”).
This Decision was issued on 22 December 2025, published in Official Gazette Issue No. 814 and entered into force 30 days from publication (28 January 2026).
It establishes a formalised domestic mechanism for the collection, retention, access and exchange of tax information pursuant to international treaties and agreements. It replaces the earlier, narrower framework under Cabinet Decision No. 17 of 2012 and aligns the UAE’s administrative processes with internationally recognised tax transparency standards.
Scope of Application
The framework applies broadly to:
- Natural persons conducting licensed commercial activities in the UAE (including free zones)
- Legal persons incorporated, registered, or licensed in the UAE (including free zones)
- Legal arrangements such as trusts, joint ventures and similar structures managed or registered in the UAE
- Persons with a Permanent Establishment in the UAE (as defined under Federal DecreeLaw No. 47 of 2022 on Corporate Tax)
Expanded Information Categories
The Decision expressly covers the retention and disclosure of:
- Ownership and identity information (including Beneficial Owner data aligned with Federal Decree Law No. 10 of 2025 AML framework)
- Banking information (including account holders, legal owners, Beneficial Owners and transactional records)
- Accounting records sufficient to determine financial position at any time
- Net asset information (movable and immovable property, assets, liabilities, revenues and returns).
This reflects a clear legislative move toward integrated tax and AML transparency compliance.
Record-Keeping and Retention Obligations
A key development is the codification of minimum retention periods:
- Information must be retained for at least five (5) years from the end of the relevant financial or calendar year
- For dissolved entities, information must be retained for at least five (5) years from the date of cessation or removal from the register
- Retention obligations extend to liquidators, trustees, controllers and persons responsible for managing legal arrangements
Importantly, information must be retained within the UAE or remain accessible from within the UAE, reinforcing domestic supervisory reach.
Regulatory Authority Powers
Regulatory Authorities are granted enhanced supervisory powers including the ability to:
- Access premises to review and audit records in cases of suspected violations
- Impose administrative fines
- Suspend, non-renew or cancel licenses in serious cases.
Administrative Penalties
The Decision introduces specific monetary penalties:
- AED 20,000 – Failure to retain information
- AED 20,000 – Failure to submit information within the specified timeframe
- AED 60,000 – Submission of false or inaccurate information
- AED 100,000 – Concealment, destruction or tampering with information
Penalties may be doubled in case of repeat violations within 12 months, and supplementary measures may include license suspension (up to 6 months), non-renewal or cancellation.
Confidentiality Safeguards
Information exchanged remains confidential and may only be disclosed in accordance with international treaties and UAE legislation. Notably, legal professional privilege is expressly preserved in relation to confidential communicationbetween clients and their lawyers in judicial or administrative proceedings.
Practical Considerations for Businesses
From a compliance perspective, this Decision significantly strengthens the UAE’s exchange of informationinfrastructure. Businesses particularly multinational groups should:
- Reassess beneficial ownership record accuracy and cross-border transparency reporting controls
- Ensure accounting systems allow full traceability of financial position at any given time
- Review internal data retention policies to confirm compliance with the five-year statutory minimum
- Align AML, UBO and tax documentation processes to avoid regulatory
This framework signals continued UAE alignment with OECD transparency standards and reinforces the expectation of substance-backed record integrity.
Our team regularly advises on tax obligations, alignment on regulatory and corporate governance and cross-border information exchange compliance. Please reach out to Suneer Kumar at suneer@alsuwaidi.ae, Vida Grace Serrano at vida@alsuwaidi.ae, or Mamdouh Tawfik at m.tawfik@alsuwaidi.ae.