Investor Reporting for UAE Funds

Investor reporting is part of the fund's tax work

Cabinet Decision No. 34 of 2025 requires a fund applying for QIF treatment to provide investors with the information, documents and data needed to calculate taxable income. Article 4 applies the same duty to a REIT applying for exemption. The investor pack is therefore not a courtesy after a dividend. It is part of the evidence that the fund can support the tax treatment it is asking the FTA to approve.

The FTA Public Clarification on investors in an exempt REIT points to the records that drive the result: Immovable Property Income, legal ownership interest, distribution status and the period in which the amount is included. A generic net asset value statement may not answer any of those questions. The signed accounts and ownership records have to connect to a per-investor schedule.

If the year has already closed, start with the signed financial statements, ownership register and distribution record. Do not begin with a polished letter. Those three objects tell you whether the pack can be calculated, whether a transfer has changed the result, and which missing record needs to be repaired before an investor files.

• Provide the data required by Cabinet Decision No. 34.
• Use legal ownership and holding dates.
• Tie calculations to signed accounts.
• Record distribution status and payment date.

The report changes with the investor, not just the fund

The reporting problem is sharpest where a QIF or REIT has UAE immovable property and corporate investors hold different interests. For a QIF other than a REIT, an Immovable Property Percentage above 10% can require a juridical investor to include 80% of prorated Immovable Property Income. For an exempt REIT, the FTA clarification applies the 80% adjustment to juridical investors as well.

One fund-level profit total cannot answer a per-investor question. The pack must follow each legal ownership interest, any change in that interest, the property-income classification and the distribution status. A foreign company may also need a separate nexus and registration analysis. The source records are common, but the tax treatment is not identical for every investor.

The mistake we see most is sending every investor the same percentage of a headline profit number. That ignores transfers, related entities, the period held and the distinction between property income and other returns. Build a bridge from the fund's signed accounts to each investor's legal interest, then write the reason for every adjustment beside the number.

• Identify every juridical investor.
• Separate UAE property income.
• Track ownership changes and holding dates.
• Keep resident and foreign questions distinct.

Give investors a pack they can trace to source

Start with the relevant fund financial year and the ownership interest held during it. Show the Immovable Property Income recognised in the financial statements, the investor's prorated amount, the 80% adjustment where the rule applies, and the distribution date and amount. For a REIT, record whether the 80% distribution was made within 9 months of the financial year-end and how the record was checked.

Keep the ownership register beside subscription and transfer records, the property-income bridge beside the signed accounts, and the distribution calculation beside the board resolution or bank record. If an investment manager amount is excluded or adjusted, identify the agreement and calculation. A reviewer should move from the pack to the source without asking the fund team to recreate the logic.

The deliverable is a tax information pack and workpaper. It is not a statutory audit, does not certify financial statements and does not replace the investor's own tax return. Exiloz can prepare the allocation and supporting schedule, while the fund manager remains responsible for approving the records and supplying them to its investors.

Close the books first, then run the investor schedule

Put the nine-month distribution window on the fund calendar as soon as the financial year closes. Close the property-income figure from the signed accounts, freeze the legal ownership register and list transfers, then calculate each investor's share. Next record the distribution decision and payment date. The order matters because a late spreadsheet should not become the source of truth for a tax return.

Worked example: the signed REIT accounts show AED 4,000,000 of Immovable Property Income and a corporate investor holds 12.5%. The illustrated 80% adjustment is AED 4,000,000 x 80% x 12.5% = AED 400,000. These amounts are examples, not statutory thresholds. The actual schedule must use the fund's accounts, legal register, holding period and distribution evidence.

Issue a preliminary schedule at book close and a final pack after the distribution resolution. Mark changes rather than overwriting the first calculation. The FTA clarification gives the tax treatment, but it does not remove the need to preserve the documents showing how this fund applied it. An investor should receive a dated answer, not a number detached from its source.

• Close the property-income bridge.
• Freeze ownership and transfer dates.
• Track the 9-month distribution window.
• Issue a dated pack to each investor.

The fee follows reconciliations, not a template

The work grows where a fund has several property entities, investor classes, transfers during the year, different year-ends or accounts that need reconstruction. One stable investor class and a clean property ledger require fewer checks. Those are the facts that should shape a professional fee. A label such as simple reporting does not tell a manager how many ownership and income bridges must be built.

The FTA clarification confirms the fund's duty to provide information needed for taxable-income calculations, but it does not specify one reporting template for every investor class, ownership history or property arrangement. That is the unsettled boundary. We would use a consistent pack, name the source behind each line, and record a judgment where the official material does not decide the edge case.

The finished file should answer four questions without reopening the ledger: what property income was recognised, who held the interest, what was distributed and when, and which tax period receives the amount. Exiloz prepares tax reporting support, but it is not a registered Tax Agent, an FTA-accredited ASP or a statutory auditor. Send the latest accounts and register first.

• Property-income bridge from signed accounts.
• Per-investor ownership schedule.
• Distribution calendar and payment evidence.
• Source note for every adjustment.