A fresh look at Unincorporated Partnerships, Foreign Partnerships, and Family Foundations under the UAE Corporate Tax Law
The UAE’s Federal Decree-Law No. 47 of 2022, along with its latest FTA Decision No. 5 of 2025, has set a new course for tax compliance among unincorporated partnerships, foreign partnerships, and family foundations. This article offers a unique, scenario-driven walkthrough of the compliance essentials, and deadlines for these entities under the UAE’s evolving corporate tax regime.
Unincorporated Partnerships:
Meaning:
The Corporate Tax Law defines an Unincorporated Partnership as a relationship established by contract between two or more Persons, in accordance with the applicable legislation of the UAE. The reference to a contractual relationship in the definition of Unincorporated Partnership means that, legally, the business of the Unincorporated Partnership and its owners is or can be considered the same.
As per the provisions of the law, the partners of the unincorporated partnership are liable for Corporate Tax in UAE i.e. the unincorporated partnership is considered as fiscally transparent. However, the law also provides for provisions wherein application can be made to the Federal Tax Authority for the unincorporated partnership to be considered as a taxable person i.e. fiscally opaque.
Compliance Checklist:
Authorized Partner Appointment: For the unincorporated partnerships which are considered as fiscally transparent, one partner must be designated to act on behalf of all partners for tax registration and filings.
The applicable compliance requirements and due dates are as under:-
Compliance |
Due Date |
Unincorporated Partnerships – Fiscally Transparent |
|
Corporate Tax Registration Application: |
31 August 2025 3 months from the end of first FY |
Submission of Annual Declaration: |
31 December 2025 9 months from the end of FY |
Tax Deregistration |
3 months from the date of cessation of business/business activity |
Unincorporated Partnerships – Fiscally Opague |
|
Application to be treated as Taxable Person: |
31 December 2025 |
Filing of Tax Return |
31 December 2025 |
Foreign Unincorporated Partnership – Fiscally Transparent |
|
Annual Declaration - to be filed by Taxable Person that is a partner in Foreign Partnership |
At the time of filing the Tax Return by the partner that is a taxable person |
Family Foundations:
Meaning:
Family foundations are legal entities created to manage and protect family assets, often for succession or philanthropic purposes.
As per the provisions of the law, a family foundation or a juridical person wholly owned and controlled by a Family Foundation can make an application to the FTA to be treated as unincorporated partnership.
The applicable compliance requirements and due dates are as under:-
Compliance |
Due Date |
Application to be treated as Unincorporated Partnership: For any FY ending before 31 December 2025 Any other FY |
31 December 2024 Before the end of the relevant FY |
Annual Confirmation For any FY ending before 31 March 2025 Any other FY |
31 December 2025 9 months from the end of FY |
The aforesaid decision is effective from 1 July 2025 and repeals the earlier FTA Decision No. 16 of 2023.
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