How Ministerial Decision No. 84 of 2025 Replaces MD 82 of 2023 — Changes to UAE Corporate Tax Audit Requirements

On 25 March 2025, the Ministry of Finance issued Ministerial Decision No. 84 of 2025, which formally repeals and replaces Ministerial Decision No. 82 of 2023 on the determination of categories of Taxable Persons required to prepare and maintain audited financial statements for UAE Corporate Tax purposes. The transition is not immediate for all periods — MD 82 of 2023 survives for Tax Periods that commenced before 1 January 2025 — but from 1 January 2025 onwards, MD 84 of 2025 is the governing instrument.

What Did MD 82 of 2023 Require?

MD 82 of 2023 established the initial categories of Taxable Persons required to prepare audited financial statements under the UAE Corporate Tax Law. It identified the AED 50 million revenue threshold for standard Taxable Persons and confirmed the obligation for Qualifying Free Zone Persons. It was the first substantive ministerial decision on audit requirements under the then-new CT regime.

Key Changes Introduced by MD 84 of 2025

The substantive framework of MD 84 of 2025 is largely consistent with MD 82 of 2023, but with important additions and clarifications:

• Non-Resident Revenue Clarification: MD 84 of 2025 explicitly addresses how the AED 50 million threshold is calculated for Non-Resident Persons — only PE/nexus revenue in the UAE counts. This was implicit before but is now expressly stated in Article 2(4).
• Tax Group Special Purpose Statements: The obligation for Tax Groups to prepare audited special purpose financial statements is now explicitly placed in MD 84 of 2025, cross-referencing MD 114 of 2023. This provides a clearer combined legal basis.
• Distribution Activity QFZPs: Article 2(3) introduces an additional compliance obligation for QFZPs engaged in distribution activities in Designated Zones — they must also comply with any FTA-prescribed additional procedures.
• Effective Date and Transition: The decision applies from Tax Periods commencing 1 January 2025, with MD 82 of 2023 remaining in force for earlier periods.

What Stayed the Same?

• The AED 50 million revenue threshold for individual Taxable Persons (not Tax Groups) remains unchanged.
• QFZPs continue to face an unconditional audit requirement.
• The audit must be performed by a licensed UAE auditor following applicable accounting standards.
• The seven-year record retention requirement continues under the Tax Procedures Law.

Transition: Which Decision Applies to Which Period?

The transition rule is clear:

• Tax Periods starting before 1 January 2025: MD 82 of 2023 applies.
• Tax Periods starting on or after 1 January 2025: MD 84 of 2025 applies.

For businesses with a fiscal year aligned to the calendar year, the first period under MD 84 of 2025 is 1 January 2025 to 31 December 2025. For entities with non-standard Tax Periods, the transition date depends on when their CT registration Tax Period commenced.

Compliance Recommendations

• Review your entity classification under MD 84 of 2025 for your 2025 Tax Period.
• If you are a Non-Resident, calculate your UAE PE/nexus revenue separately to assess the threshold.
• QFZP entities should confirm their audit engagement is in place for their current Tax Period.
• Tax Groups should coordinate with their representative member and auditor on special purpose statement requirements.

How Abdelhamid & Co. Can Help

Our firm has been advising UAE businesses on Corporate Tax compliance since the law's implementation. We help entities navigate the transition from MD 82 of 2023 to MD 84 of 2025, assess their audit obligations, and prepare fully compliant audited financial statements for the FTA.

Frequently Asked Questions

Last reviewed: May 2025 | Reference: Ministerial Decision No. 84 of 2025