English common law, applied directly
ADGM is distinctive even among financial free zones in that English common law applies directly rather than through a locally drafted code. Its courts, its companies regulations and its insolvency framework follow that lineage.
For accounting purposes the practical consequences are that company law questions are answered by ADGM regulations, financial reporting and audit requirements come from the ADGM framework and — for regulated firms — from the FSRA rulebook, and the entity types available differ from those elsewhere in the UAE.
ADGM has also become a significant home for funds, family offices, holding structures and, increasingly, virtual asset businesses. Each of those brings its own reporting profile, and the last brings questions that are genuinely unsettled in places.
What is not distinctive is federal tax, which applies here as everywhere.
Who needs it
ADGM entities across the range: FSRA-regulated financial services firms, funds and fund managers, family offices, holding companies and special purpose vehicles, professional services firms, and virtual asset businesses.
The entities where we most often find gaps are family offices, holding companies and SPVs — established for the legal framework, administered lightly, and frequently never registered for corporate tax because nobody thought of them as businesses.
How we do it
Every engagement is different in detail, but the shape is consistent:
- Map the obligations for your specific entity type: Registration Authority filings, FSRA requirements where regulated, and federal tax in every case.
- Maintain accounting records to the ADGM standard.
- Prepare financial statements under IFRS to the applicable framework.
- Coordinate audit where required, with an auditor acceptable under the ADGM or FSRA framework.
- Register and file for corporate tax, and for VAT where thresholds are met.
- Assess QFZP status, which for financial, holding and fund activities requires technical analysis rather than assumption.
- Support FSRA regulatory reporting, including capital adequacy where applicable.
- Maintain the registers, including beneficial ownership.
Funds, family offices and SPVs
ADGM’s structuring populations each raise a distinct set of questions, and the answers do not transfer between them:
- Funds and fund managers — fund accounting and NAV calculation sit alongside the manager’s own reporting; the two should not be conflated
- Family offices — typically low transaction volume with substantial assets, where the corporate tax and substance questions matter more than the bookkeeping
- Holding companies and SPVs — the population where corporate tax registration is most often missed entirely, and where the penalty applies per entity
- Virtual asset businesses — accounting treatment for digital assets is an area where guidance is still developing, and positions should be documented with their reasoning rather than simply adopted
- Regulated firms — FSRA reporting is additional to and more demanding than the Registration Authority’s requirements
The third of these is where the money is lost. An SPV inside a larger structure, doing nothing visible, still registers and still files — and the AED 10,000 late-registration penalty applies to it as to anything else.
Abu Dhabi rather than Dubai
ADGM sits in Abu Dhabi, and for a group with entities in both emirates that has practical consequences beyond geography.
Abu Dhabi mainland licensing runs through ADDED rather than Dubai’s DET, with its own requirements and timelines. A group holding an ADGM entity, an Abu Dhabi mainland company and a Dubai free zone company is dealing with three different licensing regimes on three different calendars, plus one federal tax regime that treats them as related parties.
That combination is where transfer pricing, tax grouping and related party documentation stop being theoretical. Intercompany service arrangements between an ADGM entity and a Dubai affiliate are related party transactions requiring arm’s length pricing and documentation, whatever the internal view of them is.
- Abu Dhabi mainland licensing through ADDED, not DET
- ADGM’s own Registration Authority for zone entities
- One federal tax regime across all of them
- Intercompany arrangements between emirates are still related party transactions
- Tax group eligibility requires common financial year ends across members
Where this goes wrong
The same problems recur, and every one of them was cheaper to prevent:
- Treating ADGM compliance as the whole obligation and missing federal corporate tax.
- SPVs and holding companies left unregistered, which is where the penalty most often lands.
- Applying federal companies law reasoning to a common-law jurisdiction with its own regulations.
- Assuming financial and fund activities qualify for 0 per cent without the analysis.
- Family offices with nominal substance claiming a status that depends on substance.
- Intercompany arrangements across emirates with no transfer pricing basis.
- Regulated firms conflating FSRA reporting with financial reporting, when the first is additional.
The timing
Registration Authority filings follow the ADGM calendar for your entity type. Federal corporate tax is due nine months after the tax period ends — 30 September 2026 for a December year end.
The QFZP and substance analysis belongs early in the period, because substance cannot be created retrospectively: board meetings, presence and expenditure must actually have occurred during the period they are relied on for.
Deliverables
- An obligations map across Registration Authority, FSRA and federal tax
- Accounting records to the required standard
- IFRS financial statements and audit coordination
- Corporate tax registration and filing for every entity in the structure
- QFZP analysis with the qualifying activity assessment documented
- Transfer pricing documentation for intercompany arrangements
- Registers maintained, including beneficial ownership
Documents we will ask for
Nothing exotic, and most of it you already have:
- ADGM registration and entity type details
- FSRA licence details where regulated
- Trial balance and general ledger
- Details of activities and income by type
- Group structure, including entities in other emirates
- Intercompany arrangements and agreements
- Substance evidence: premises, personnel, board meetings
- Corporate tax registration status for every entity
Fees
Quoted on entity type and activity level. A holding company or SPV with minimal transactions is a light recurring engagement; a regulated firm with FSRA reporting is considerably more.
For groups with several ADGM entities, we quote across the structure rather than per entity, because much of the work — ownership mapping, intercompany documentation, transfer pricing — is done once and applies to all of them.
Related
Frequently Asked Questions
Do ADGM entities pay UAE corporate tax?
Yes. Corporate tax is federal and applies to ADGM entities on the same terms as everyone else. An entity may qualify as a Qualifying Free Zone Person and pay 0 per cent on qualifying income, but it registers and files regardless of the rate.
Is ADGM compliance the same as federal compliance?
No. The Registration Authority governs company filings and accounts; the Federal Tax Authority governs corporate tax and VAT. An entity in good standing with the Registration Authority and unregistered for corporate tax has met one obligation and missed another entirely.
Does our SPV need to register for corporate tax?
Almost certainly. SPVs and holding companies are where the late-registration penalty most often lands, precisely because they do nothing visible and nobody looks at them. The AED 10,000 penalty applies per entity.
What is different about ADGM’s legal framework?
English common law applies directly rather than through a locally drafted code, with ADGM’s own courts, companies regulations and insolvency framework. Company law questions are answered by ADGM regulations. Federal tax is unaffected by any of that.
How are digital assets accounted for?
It is an area where guidance is still developing, and the honest position is that some questions do not yet have settled answers. What we do is document the position taken and the reasoning behind it, so that it can be explained and, if necessary, revisited — rather than adopting a treatment silently.
We have entities in ADGM and Dubai. Does that complicate things?
It means three licensing regimes potentially — ADGM’s Registration Authority, ADDED for Abu Dhabi mainland, DET for Dubai mainland — on different calendars, under one federal tax regime that treats them all as related parties. Intercompany arrangements between them require arm’s length pricing and documentation.
Do funds need separate accounting from the manager?
Yes. Fund accounting and NAV calculation are distinct from the manager’s own financial reporting, and conflating them is a common error in smaller structures. Each has its own requirements and, where regulated, its own FSRA obligations.
SPVs and holding companies are where corporate tax registration is most often missed, and the penalty applies to each one. Send us the structure.
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Last reviewed 27 July 2026. Rates, thresholds and deadlines change — the e-invoicing provider deadline has already moved once. Confirm current requirements with the Federal Tax Authority before acting, or ask us to check your position.