Exchange of Information upon Request for Tax Purposes

The UAE Ministry of Finance has issued Cabinet Resolution No. (209) of 2025, establishing a comprehensive framework for the Exchange of Information upon Request (EOIR) for tax purposes. The Resolution reinforces the UAE’s commitment to international tax transparency, strengthens cooperation with foreign tax authorities, and aligns the country’s regulatory framework with globally recognized OECD standards to combat tax evasion and enhance compliance.

Most Double Taxation Avoidance Agreements (‘DTAAs’) have an Exchange of Information clause that allows tax authorities of two countries to share tax related information to prevent tax evasion, detect undisclosed foreign income/assets, promote tax transparency and ensure proper tax compliance.

The Resolution implements the UAE’s obligations under international tax treaties and Exchange of Information (EOI) standards significantly strengthening compliance and enforcement.

Objective of the Resolution
The primary objective of Resolution is to:

• Regulate the procedures for exchanging tax-related information upon request.
• Ensure compliance with international tax treaties and agreements.
• Promote transparency and prevent tax evasion.
• Define the responsibilities of competent authorities and relevant entities.
• Establish safeguards for confidentiality and data protection.

Scope of Application:

Information Exchange Mechanism

• The Ministry shall request and collect information and documents, whether directly or indirectly through any governmental entity or regulatory authority, in the manner and within the period determined by the Ministry, and such information shall be exchanged with the competent foreign authorities upon their request, and within the limits required by the international treaties and conventions concerned with the request for information.
• “Information” is defined as Ownership information, identity, banking information, accounting records, information on net assets, and any other information specified by the Minister.
• The Ministry of Finance (MoF) serves as the designated central competent authority for gathering and transmitting information and coordinating with government entities and regulatory authorities.
• Regulatory authorities (including free zone authorities and licensing bodies) play an essential function and have powers to collect, validate and oversee compliance with information requests and furnish the information to the MOF as and when requested.
• Confidential information provided by clients to lawyers or legal representatives is excluded from disclosure only where it relates to representation before courts, arbitration, mediation, judicial or administrative proceedings or providing legal opinion.

Record-Keeping and Retention Obligations

All Persons in scope of the said Resolution are required to maintain the following records for a period of at least 5 years from the end of the financial year to which the information relates to:-

• Ownership and Identity documents
• Accounting Records
• Net Asset Information
• Any other information prescribed by the Minister

Administrative Violations and Penalties

Administrative fines for non-compliance are substantial and include:

In addition to the fines, the regulatory authorities may suspend the license, registration or permit for period up to six months.

Conclusion

In conclusion, Cabinet Resolution No. (209) of 2025 significantly enhances the UAE’s tax transparency framework by expanding the scope of information that may be collected and exchanged with foreign tax authorities under international treaties. The introduction of stricter record-keeping requirements and substantial administrative penalties increases compliance scrutiny and enforcement risk, including the possibility of license suspension or cancellation.

Businesses are therefore advised to proactively review and strengthen their internal governance, compliance controls, and record-retention practices to ensure readiness under this reinforced regulatory regime.