Trusts, funds and similar financial entities

Mixed · depends on counterparty

Forensic Analysis

DZ requiredSubstance: HIGHAI-derived

Entities under ISIC 6430 often straddle the line between 'Exempt Persons' under Article 10 and 'Qualifying Free Zone Persons'. Forensic scrutiny focuses on whether the entity is a 'Passive Investment Vehicle' or an active 'Financial Business'. Under MD 229 of 2025, the FTA will verify if the income is derived from 'Holding of Shares and Other Securities' (Qualifying) versus 'Financial Brokerage' or 'Banking' (Excluded).

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Legal Reference

Article 10 of Federal Decree-Law No. 47 of 2022 and MD 229 of 2025 Clause 4

Audit Red Flag

Misclassification of 'Excluded Activities' as 'Qualifying Income' when the entity provides financial services to non-related parties or acts as a conduit for non-resident beneficial owners.

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