UBO register filing UAE: Stricter disclosures and the new compliance reality
The United Arab Emirates has evolved from an outsider in the global tax framework into an active participant. Companies operating there must now adhere to compliance regulations. Ecovis consultants explain what needs to be considered and verified.
Ten years ago, a multinational concern structuring operations through the UAE could expect limited scrutiny: no corporate tax, no transfer pricing rules of substance, no country-by-country reporting, and limited exchange of information. That position has changed substantially.
UAE complies with OECD rules
The UAE is now a member of the OECD Inclusive Framework on BEPS, with CbCR in force under Cabinet Resolution 32 of 2019. Federal corporate tax at 9% has applied since June 2023, with a full transfer pricing regime regulated by the FTA (Federal Tax Authority). From January 2025, a domestic minimum top-up tax of 15% applies to MNE groups with consolidated revenues above EUR 750 million.
At the same time, the beneficial ownership and AML regime has been overhauled. The UBO register (UBO=Ultimate Beneficial Owner) – introduced under Cabinet Decision 58 of 2020 and strengthened by Cabinet Decision 109 of 2023 – made beneficial ownership filing mandatory for mainland and commercial free zone companies. The UAE was placed on the FATF (Financial Action Task Force) grey list in March 2022 and removed in February 2024, reflecting the depth of legislative and supervisory reform.
For cross-border engagements, we collaborate with other Ecovis firms and can offer services such as corporate taxation in the UAE, transfer pricing, and statutory audits.
Rashmi Rajkumar, Co-Founder & Partner, ECOVIS JRB Chartered Accountants, Dubai, United Arab Emirates
The significance for businesses operating in the UAE
- Group structures built before 2019 – including ADGM and DIFC holding entities and free zone operating companies – should be reviewed against Pillar Two and the QFZP rules. The economic rationale, not just compliance, may have shifted.
- Transfer pricing documentation prepared at authorisation but not updated since is increasingly exposed. FTA audit activity is rising.
- UBO transparency now affects banking, counterparty due diligence and transaction execution well beyond regulatory filing.
Recommendations for businesses
The 2023–2025 reset is now fully in force. Structures, transfer pricing documentation and ownership disclosures built for the pre-framework UAE are overdue for a fresh review against the rules as they stand today.
