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UBO Compliance Servicesin the UAE
UBO registration UAE requirements are not just a one-time form.
Your company needs the correct beneficial owner identified, the required registers prepared, the right information filed with its registrar, and ownership changes updated on time. Bestax handles the process from ownership review to filing and ongoing compliance support.
- FTA Approved
Tax AgencyNo. 30008692 - Business Setup Partner
for Dubai Free Zones - 10+YEARSof Experience
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Talk to a
UBO Consultant
Tell us your licence type, your registrar and how your shares are held, and we will confirm which UBO framework applies to you and what has to be filed.
Recognition, Accreditations & Partnership
The approvals and registrations behind the work.
IFZA Gold Tier Partner Recognition
Gold Tier Recognition · Elite Loyalty Programme
Accounting Software Experience
Hands-on Experience Across Leading Accounting Platforms
ICAEW Approved Employer
Supporting Professional Training and Development
KIZAD
Business Setup Partner in Abu Dhabi
Meydan Free Zone
Company Formation Partner in Dubai
SHAMS — Sharjah Media City
Business Setup Partner in Sharjah
Sharjah Publishing City
Free Zone Company Formation Partner
Payoneer
Referral Partner for International Payments
The Service
UBO Compliance Services for UAE Companies
Bestax provides UBO compliance services that cover the full ownership disclosure process, not only the initial submission.
We first establish who controls the company, then prepare the records and filing information required by the relevant registrar.
What the service covers
- UBO scope reviewWe confirm whether the federal UBO resolution applies to your company or whether a separate financial-free-zone framework applies.
- Ownership tracingWe trace direct and indirect ownership through holding companies, trusts, nominees and other layers to identify the natural person who ultimately owns or controls the entity.
- UBO register preparationWe prepare the beneficial owner register with the required identity, ownership and control information.
- Partners or shareholders registerWe organise shareholder or partner information and update the register when ownership changes.
- Declaration and registrar filingWe prepare the declaration and coordinate submission through the relevant licensing authority or registrar.
- Change updatesWe update ownership, control and register information when a reportable change occurs.
- Complex structure supportWe map ownership layers and prepare supporting evidence for companies with several legal entities or jurisdictions in the ownership chain.
- Inspection and remediation supportWe review existing records, identify missing information and correct gaps before they become repeated compliance failures.
If your ownership review also raises wider financial-crime compliance issues, Bestax can connect the work with our AML Compliance Services in Dubai so the UBO file and AML records use consistent ownership information.
Who Is In Scope
UBO Compliance UAE Requirements Bestax Handles
The current federal framework is Cabinet Resolution No. 109 of 2023 Regulating the Real Beneficiary Procedures. It replaced Cabinet Resolution No. 58 of 2020. The rules apply to legal persons licensed or registered in the UAE, subject to the exclusions in the resolution.
Our UBO compliance UAE service checks the company against the current rules before preparing a filing. This matters because not every UAE entity follows the same federal route.
Mainland legal persons
Most mainland legal persons fall within the federal framework.
Commercial free zones
Commercial free-zone legal persons generally fall within the federal framework and file through their relevant registrar.
Financial free zones
Financial free zones are excluded from Cabinet Resolution No. 109 of 2023 and follow their own beneficial ownership frameworks.
Government-owned companies
Companies wholly owned by the Federal or Local Government, and companies wholly owned by those companies, are excluded from the federal resolution.
The government-partner exclusion
The resolution also contains a government-partner exclusion that must be checked against the company structure.
DIFC and ADGM are financial free zones with separate beneficial ownership requirements. ADGM, for example, applies its Beneficial Ownership and Control Regulations to entities within its own framework. Bestax confirms the correct regulator before treating a company as covered by the federal rules.
Article 5
Bestax Identifies the Correct Beneficial Owner Before Filing
A UBO is always identified by looking through the legal ownership to the natural person who ultimately owns or controls the entity. Bestax applies the identification sequence in Article 5 before preparing the register.
25% of the capital
A natural person who directly or indirectly owns 25% or more of the company capital can qualify as the beneficial owner.
25% of the voting rights
A natural person with 25% or more of the voting rights can qualify as the beneficial owner.
Control through other means
Control can also exist through other means, including the right to appoint or remove the majority of the board.
Where ownership alone is not enough
If ownership alone does not identify the correct natural person, control through other means is considered.
The senior management position
If no natural person is identified after the required ownership and control analysis, the natural person holding the senior management position is treated as the beneficial owner under the resolution.
More than one beneficial owner
More than one natural person can be recorded where more than one person meets the ownership or control test.
For group structures, we do not stop at the first corporate shareholder. The resolution requires the beneficial owner to be traced through any number of legal persons or arrangements, and complex structures can create separate disclosure risk if the ownership layers are not properly identified.
UBO Register UAE: What Bestax Prepares and Maintains
A UBO register UAE file needs more than the owner name and share percentage. Bestax prepares the register with the information required under Article 8 and keeps the supporting ownership evidence organised for future updates or registrar requests.
| Register Detail | What Bestax Checks |
|---|---|
| Identity | Full name, nationality, date and place of birth |
| Contact address | Residence or address for notices |
| Identification document | Passport or ID number, issuing state, issue date and expiry date |
| Reason for UBO status | Ownership, voting rights, control or other basis used to identify the person |
| Start date | Date the person became the beneficial owner |
| End date | Date the person stopped being the beneficial owner, where applicable |
The two statutory clocks
- 60 daysTo create the register
A legal person must create its beneficial owner register within 60 days from the date the entity comes into existence under the current resolution. The company must also provide the beneficial owner register and the partners or shareholders register data to its registrar within the applicable 60-day period from licensing or registration.
- 15 daysTo update it after a change
When the company becomes aware of a change in the beneficial owner register, it must update the register within 15 days. Article 15 also requires changes to information under the resolution to be submitted to the registrar within 15 days from the amendment or change.
If your corporate records and accounting files do not match the ownership structure, Bestax can align the compliance file with our Accounting and Bookkeeping Services in Dubai before an audit, bank review or authority request exposes inconsistencies.
The Filing
UBO Declaration UAE: Filing and Updates With Your Registrar
There is no single filing route that works for every company. A UBO declaration UAE submission is handled through the registrar responsible for the legal person. That can be a mainland licensing authority or the relevant commercial free-zone authority.
Bestax first confirms the registrar, then prepares the ownership information and the authority-specific filing. We also check whether the same UBO information must be refreshed during incorporation, licence renewal, amendment or another registrar procedure.
Confirm the licensing authority and applicable UBO framework.
Collect shareholder, partner and beneficial owner documents.
Map direct and indirect ownership percentages.
Identify control rights and nominee relationships.
Prepare the beneficial owner register and partners or shareholders register.
Prepare the authority-specific declaration or portal data.
Coordinate the filing with the relevant registrar.
Keep an update calendar for ownership, director and shareholder changes.
For a new company, Bestax can build the ownership file during Business Setup in Dubai so the licensing documents and beneficial owner information start with the same ownership structure.
If the structure is an offshore vehicle, our Offshore Company Setup in Dubai service can coordinate the company file and the ownership disclosure requirements together.
Documents Bestax Reviews for UBO Registration
The exact documents depend on the company structure and registrar. We confirm the final list before asking you to prepare or legalise documents.
- Valid passport or Emirates ID for each beneficial owner
- Proof of address where requested by the registrar
- Current trade licence and incorporation documents
- Memorandum and Articles of Association
- Current shareholder or partner register
- Group ownership chart for corporate shareholders
- Parent-company incorporation documents where relevant
- Share certificates, shareholder agreements or other evidence of ownership and control where required
- Nominee director or nominee shareholder information where applicable
- Authorisation documents for the UAE-resident natural person appointed to disclose required information to the registrar
Layered Structures
Complex Ownership, Nominee Arrangements and Group Structures
Layered structures need more work because the legal shareholder shown on a licence is not always the natural person who ultimately controls the company. Bestax traces the structure until the natural person is identified under the ownership and control tests.
A risk-based approach is required
Cabinet Resolution No. 109 of 2023 specifically requires a risk-based approach for complex structures. The current penalty schedule also treats failure to disclose the ownership layers of a beneficial owner in a complex ownership structure as a separate violation.
Nominee arrangements must be documented
Nominee arrangements also need to be documented correctly. Board nominee members have disclosure duties, and the partners or shareholders register needs to show the relevant nominee or trustee information required by the resolution.
15 Days
15-Day UBO Updates After Ownership or Control Changes
A UBO file cannot stay unchanged after a share transfer, group restructuring, voting-right change or change in control. Bestax reviews the transaction and updates the beneficial owner and shareholder records within the applicable reporting timeline.
We can support changes involving new shareholders, transfers between group companies, director or nominee changes, revised ownership percentages, changes in control rights, and a person starting or ceasing to qualify as the beneficial owner.
- New shareholders
- Transfers between group companies
- Director or nominee changes
- Revised ownership percentages
- Changes in control rights
- A person starting or ceasing to qualify as the beneficial owner
UBO Penalties Bestax Helps You Avoid
Cabinet Resolution No. 132 of 2023 contains the current administrative penalty schedule for violations of Cabinet Resolution No. 109 of 2023. The penalties increase for repeated violations, so leaving the same gap unresolved creates a bigger compliance risk.
| Example Violation | First Violation | Second Violation | Third Violation |
|---|---|---|---|
| Failure to properly register beneficial owner details | Written warning | AED 20,000 | AED 40,000 |
| Failure to establish and maintain the beneficial owner register | Written warning | AED 50,000 | AED 100,000 |
| Failure to update the beneficial owner register | Written warning | AED 15,000 | AED 30,000 |
| Failure to provide additional data requested by the registrar within 14 days | Written warning | AED 15,000 | AED 30,000 |
| Failure to disclose ownership layers in a complex ownership structure | Written warning | AED 50,000 | AED 100,000 |
| Failure to establish the partners or shareholders register | No first-violation fine listed in the schedule | AED 50,000 | AED 100,000 |
The exact violation and enforcement step should be checked against the authority notice and Cabinet Resolution No. 132 of 2023. Bestax reviews the company file, identifies the missing requirement and prepares the corrective work before the issue becomes a repeated violation.
UBO Compliance During Company Renewal and Amendments
UBO compliance is connected to the company licence file. Article 11 requires legal persons to provide basic company data to the registrar during incorporation, licensing, registration, renewal, modification and other procedures required by the registrar.
When Bestax handles a company update, we can review the beneficial owner data at the same time. This reduces the risk of the trade licence, shareholder records, UBO declaration and group chart showing different information.
If the company is changing or renewing its setup, Bestax can coordinate the ownership review with our Dubai Mainland Business Setup service or the relevant free-zone process.
For free-zone companies, our Dubai Free Zone Business Setup service can keep licensing and UBO information aligned when the structure changes.
UBO Records for Audit, Banking and AML Reviews
Beneficial ownership information is not just a licensing record. Banks, auditors and regulated businesses use ownership information when they complete customer due diligence and understand who controls a company.
Bestax keeps the UBO register, shareholder information and supporting ownership documents organised so the company can respond more quickly when a bank, auditor or authority requests evidence of the ownership chain.
Where the business also needs financial statement or control assurance, the ownership file can be coordinated with our Auditing Services in Dubai so the corporate records and audit evidence remain consistent.
Why Bestax
Why Businesses Choose Bestax for UBO Compliance
- 10+ years supporting UAE businesses with accounting, compliance and company services
- 35+ professionals across accounting, audit, tax and business support
- Experience supporting more than 1000 clients
- Current-law review based on Cabinet Resolution No. 109 of 2023, not the repealed 2020 resolution
- Ownership tracing for direct, indirect and complex structures
- Authority-specific filing rather than a one-size-fits-all declaration
- Ongoing update support when shareholders, control or company information changes
- Connected support for AML, accounting, audit, business setup and offshore structures
Our Strength in Numbers
10+Years
UAE accounting and compliance experience
35+Professionals
Accounting, audit and compliance team
1,000+Clients
Businesses supported across the UAE
What Clients Say About Bestax
We believe our work speaks for itself. Our clients say it louder. Businesses across the Emirates trust Bestax to keep their records accurate, current and correctly filed.
Had my first corporate tax filing done through Bestax. They offered a tax planning session that was extremely helpful, especially because I was unsure what expenses could be deducted legally. They kinda guided me through the whole process because, as a healthcare professional, I had no clue how things work around here.
I'm very pleased with the support provided by Athira and her team in completing my Transfer Pricing report and filing the Corporate Tax returns for my company. They are highly responsive, and the quality of their work and reports is truly excellent.
Very smooth and efficient service to open a freezone company. Even while sitting in canada. They are great. Highly highly recommend.
Bestax have been managing my accounts for the past 1 year now and I must say they do an amazing job. My tax returns are always on time and I never faced any penalty.
Maham guided me through the business license renewal process. She even flagged upcoming compliance changes I had no clue about. It’s that extra attention to detail that makes Bestax stand out.
Anusha at Bestax keeps our financials in top shape. Her budgeting advice has improved our cash flow significantly. Highly reliable team!
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