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UAE REIT Taxation

UAE REIT Taxation

With the UAE Corporate Tax regime now in force, Real Estate Investment Trusts (REITs) qualifying as Qualifying Investment Funds (QIFs) continue to enjoy corporate tax exemption.
But here’s the critical shift 👇
👉 The tax liability doesn’t disappear — it moves to the investor.

Key Insight from FTA Clarification (CTP005):

🔹 80% Rule for Corporate Investors
If a REIT is exempt, juridical (corporate) investors must include 80% of their proportionate share of immovable property income in their taxable income.
🔹 Applies from 1 Jan 2025
This treatment is applicable for tax periods starting on or after 1 January 2025.
🔹 What is “Immovable Property Income”?
It includes net realised profits from:
• Rental income
• Sale/disposal of UAE real estate
• Leasing, subleasing, or exploitation of property
🔹 Distributing vs Non-Distributing REITs
• If ≥80% income is distributed within 9 months → Tax triggered at time of distribution
• If not → Tax applies based on ownership period, even without distribution
🔹 Individuals? No Impact ✅
Natural persons are not required to include REIT income in taxable income — even if held as part of business.
🔹 No Double Taxation
Distributions received are excluded from taxable income (since already taxed via attribution).
🔹 Foreign Investors = Nexus Risk
Non-resident corporate investors may create a taxable presence (nexus) in the UAE depending on distribution patterns.

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