Cabinet Decision No. 209 of 2025, issued by the UAE Ministry of Finance, strengthens the legal framework the country uses to share tax information with foreign authorities when they formally request it. It puts Exchange of Information on Request (EOIR) — a targeted, government-to-government process — on a firmer footing, setting out what data can be shared, which bodies must supply it, and how a request can be challenged.
Key takeaways
- Cabinet Decision No. 209 of 2025 was issued by the UAE Ministry of Finance to reinforce the country's Exchange of Information on Request (EOIR) framework, in line with international tax-transparency standards.
- It clarifies the categories of information that can be exchanged: ownership and identity data, banking information, details of legal entities and legal arrangements, and accounting records.
- Government entities and regulators are tasked with collecting, holding and providing this information to the Ministry of Finance, which acts as the channel for exchange with foreign counterparts.
- The Decision builds in proportionate administrative procedures and a clear grievance route for handling disputes or concerns about a request.
- It deepens the UAE's cooperation with foreign tax authorities and global bodies such as the OECD, and underpins later confidentiality changes in the Tax Procedures Executive Regulations.
What is Exchange of Information on Request?
EOIR is what happens when a foreign tax authority investigating one of its taxpayers asks the UAE for specific information relevant to that case — for example, who really owns a UAE company, or what a UAE bank account shows. It is targeted rather than automatic or bulk: a foreign authority must make a defined request, and the UAE responds through a single competent authority. In practice, that means the ownership, banking and accounting records of UAE-based entities can be requested and, where the conditions are met, disclosed abroad.
For businesses, the shift is less about a new tax and more about visibility. Information that once felt purely domestic can now be routed to a foreign investigator through a formal, standardised process.
What information can be shared?
The Decision spells out four broad categories that fall within scope.
| Category | What it typically covers in practice |
|---|---|
| Ownership and identity data | Shareholders, beneficial owners, and who ultimately controls an entity |
| Banking information | Account details and financial records held by UAE banks |
| Legal entities and arrangements | Structural details of companies, partnerships, foundations and trusts |
| Accounting records | Financial statements, ledgers and supporting documentation |
The practical message is that beneficial-ownership and accounting records should be treated as potentially disclosable. Entities that keep this information current and reconciled are far better placed than those that would need to reconstruct it after a request arrives.
Who collects and provides the information?
The Decision assigns defined roles to government entities and regulatory authorities: they collect, hold and provide the relevant information to the Ministry of Finance. The Ministry then handles the exchange with the requesting foreign authority. This matters because it removes ambiguity about which body does what, and it means a request can draw on data already held across several UAE regulators rather than a single source.
Safeguards and how a request can be challenged
Cabinet Decision No. 209 of 2025 also sets out safeguards alongside the disclosure machinery. Administrative procedures are to be proportionate, and there is a clear grievance route for anyone who wishes to dispute a request or raise a concern about how it is handled. In other words, the framework is not one-directional — it pairs the duty to provide information with a defined mechanism to contest a request that appears improper or disproportionate.
A foreign authority's request can reach ownership, banking and accounting records the moment it is made — so the file has to be in good order before it arrives, not assembled afterwards.
What it means in practice for record-keeping
Record quality carries the practical burden here: a request can arrive at any time and reach several categories of data at once, so the pressure sits on day-to-day records rather than on any single filing. An entity that can readily produce a current register of shareholders and beneficial owners, reconciled bank records and complete accounting files is positioned to respond within the framework's timelines. One that cannot may face delay, follow-up questions and closer scrutiny — not because it has done anything wrong, but because the information is hard to assemble. In practice, SBC advisers keep a client's beneficial-ownership register and bank reconciliations review-ready year round, so an EOIR request becomes a retrieval task, not a scramble.
Why it matters for UAE businesses
The Decision reinforces the UAE's standing as a cooperative, transparent jurisdiction and supports its relationships with the OECD and foreign tax administrations. It also connects to the broader reform of the Tax Procedures Executive Regulations: later amendments realign the confidentiality rules with this exchange-of-information framework, tightening how information, once shared, may be used by receiving authorities. For groups with cross-border operations, the sensible response is to assume that data held in the UAE could be requested, and to make sure structures, records and international tax positions would withstand outside review.
Frequently asked questions
What is Cabinet Decision No. 209 of 2025?
Cabinet Decision No. 209 of 2025 is a UAE Cabinet Decision that strengthens the legal framework for Exchange of Information on Request (EOIR), the process by which the UAE shares tax information with foreign authorities when they formally request it. It clarifies the data in scope, the roles of UAE bodies, and the safeguards that apply.
What information can UAE authorities exchange with foreign tax authorities?
Four categories are covered: ownership and identity data, banking information, details of legal entities and legal arrangements, and accounting records. The information is provided to the Ministry of Finance, which handles the exchange with the requesting authority.
Does EOIR mean my company's data is shared automatically?
No. EOIR is request-based, not automatic. A foreign authority must make a specific, targeted request connected to a case it is examining. The UAE then responds through its competent authority within the framework's rules.
Can a business challenge an information request?
Yes. The Decision provides for clear grievance procedures to handle disputes or concerns, so an affected party has a defined route to contest how a request is made or handled. Read more in our general tax FAQs.
How SBC Tax Consulting can help
SBC helps UAE businesses prepare for an environment where information can cross borders on request. We review group structures, beneficial-ownership records and accounting documentation for readiness, advise on international tax exposure, and support responses to information requests and any tax disputes that follow. To assess how Cabinet Decision No. 209 of 2025 affects your business, contact our team.
This publication is for general information only and does not constitute professional advice. Please consult your SBC advisor before acting on any matter covered here.