Tax Services

Yes, a licence is required if tax services are provided by way of business to third parties. There is a general prohibition provision contained in Section 1 of the Commercial Licensing Regulations 2025, which states that no person may carry on a controlled activity in or from ADGM unless they are a licensed person or an exempt person.

Tax services is a controlled activity when offered commercially to third parties. Accordingly, any person carrying on this activity must hold a valid ADGM licence to conduct this economic activity in ADGM.

A licence is not required where tax-related activities are undertaken solely as an internal or in-house function for proprietary purposes, i.e., where a company’s accounting or finance in-house division performs tax work exclusively for the entity or its group, or as intra group services, and such services are not provided to third parties by way of business.

Tax services are defined under the Controlled Activities Rules.

"Providing tax services" means the application of tax principles or judgement with regard to the circumstances of another person, including but not limited to the following:

(a) giving tax advice to such a person in relation to tax matters in jurisdictions outside the United Arab Emirates, such as tax planning, compliance, structuring, and risk management to help such a person optimize their tax position and meet international tax obligations, or

(b) advising or representing such a person in matters related to United Arab Emirates tax, such as tax compliance, filings, advisory services, and communications with local tax authorities.

Applicants applying to carry on tax services may select one or both of the following business activities, depending on their proposed business model:

Assisting an entity with basic administrative steps to create or deactivate an account on the FTA’s online portal may not, in itself, require a licence for the ‘Provision of Tax Agent Services’ (#6920007).

However, if the assistance goes beyond purely administrative facilitation, the activity may fall within regulated tax services. This may include situations where:

• Your firm inputs, prepares, verifies or submits information to the FTA on behalf of the entity;
• The submission is made in your firm’s name or capacity, or you are otherwise acting as an intermediary or representative;
• The FTA reasonably understands that you are acting as an agent for tax purposes or providing tax-related representations;
• Your firm provides interpretation, advice or judgement regarding tax-relevant information as part of the registration; or
• The registration step is part of a broader suite of tax compliance or advisory support.

In such cases, your firm may be engaging in activity that requires a licence for the ‘Provision of Tax Agent Services’. Please note that the list provided is not intended to be an exhaustive list of every situation that may require such a licence.

With the introduction of tax services as a controlled activity, firms already licensed to conduct ‘Tax Consultancy Activities’ in ADGM must ensure that they meet the conditions of licence that have been introduced under Rule 15(2) in the Commercial Licensing Regulations (Conditions of Licence and Branch Registration) Rules 2025(B) (the “Conditions of License Rules”) upon renewal of their licence.

With respect to obtaining and maintaining adequate professional indemnity insurance, such firms have six months from 28 October 2025 to comply. Regarding compliance with principles of conduct and the Commercial Licensing Regulations (Client Money) Rules 2021, the obligation to comply took immediate effect from 28 October 2025. For further information on the rules governing tax services, see the next question.

Furthermore, such licensed firms must apply for a ‘Provision of tax agent services’ licence if needed.

Tax services are governed by the Conditions of License Rules.  This rule is available on the ADGM website here: Conditions of License Rules.  Further, it is advisable to read the Controlled Activities Rules as well.  The rule is available on the ADGM website here: Controlled Activities Rules.

The Conditions of License Rules:

• specify the eligibility criteria for applicants seeking to carry on the controlled activity of tax services in ADGM;
• prescribe the minimum professional qualifications, post-qualification experience, and professional membership standards applicable to such applicants;
• ensure that fit, proper, and professionally competent individuals and firms are licensed to provide tax services in ADGM; and
• prescribe ongoing obligations, such as compliance with the Commercial Licensing Regulations (Client Money) Rules 2021 and maintaining professional indemnity insurance, as well as any other conditions, requirements or directions specified in writing by the Registration Authority from time to time.

Applicants are required to submit sufficient information and documentation to demonstrate compliance with the licensing requirements for tax services. This typically includes the following, as well as any other information and supporting evidence that may be requested by the Registrar from time to time:

I. Management team information

An applicant must ensure that at least half of its directors, partners, managers, or individuals of equivalent standing operating under the tax services licence:

• each have a minimum of five (5) years of relevant post-qualification experience; and
• each hold a recognised professional qualification issued by a recognised professional body.

A. Information and Documents Required

Submit details of all individuals responsible for the management and provision of tax services.

• Provide a management structure chart illustrating reporting lines and responsibilities.
• For each member of the management team, submit the following documentation:
  (a) Copies of recognised professional qualifications;
  (b) Evidence of active membership with a recognised professional body, including membership certificates, good standing certificates, or other relevant supporting documents;
  (c) Evidence of relevant post-qualification experience, which must include documentary support and may comprise:

  i. Résumé outlining roles, responsibilities, and the duration of experience following professional qualification;

  ii. Employment or experience certificates;

  iii. Reference letters from previous employers; and

  iv. Employment contracts, where applicable.

II. Professional Indemnity Insurance

Applicant must, either before or promptly upon the grant of a licence, obtain and maintain professional indemnity insurance with a minimum coverage of USD 1,000,000 per single claim.

Applicants must submit confirmation from the insurer demonstrating that:

• The professional indemnity insurance policy covers the ADGM entity; and
• The scope of coverage relates to the provision of tax services.

To apply for a tax services license, a Service Request (SR) for entity incorporation/ registration must be submitted by selecting the relevant business activity code(s) (6919 and/or 6920007).

The SR must be supported by the tax services form.

The completed form must be accompanied by the relevant documents required to assess applicant’s eligibility to carry on the selected business activities.