The first 90 days with a fractional head of tax: what a UAE family office or group should expect

In the first 90 days a fractional head of tax builds a tax agenda for you, checks the UAE obligations that carry penalties, agrees an action plan with an owner for each item and sets the reporting schedule. By day 90 you should have three documents you didn’t have before: a tax agenda, an action plan and a reporting schedule. Nothing about the work needs a full-time hire, but it does need access to people and papers from the first week.

The order below is typical for a UAE family office or founder-led group, but the scope in your mandate decides how far each step goes.

Days 1 to 30: what does the head of tax need to see?

The first month is reading and asking, and a fractional head of tax usually asks for:

• a list of every company, foundation, trust and partnership, with where each is incorporated and who its directors are;
• the corporate tax registration and tax period for each UAE entity, and the latest returns filed;
• VAT registrations and recent returns;
• any letters from the Federal Tax Authority (FTA) or a foreign tax authority in the last few years;
• the agreements behind related-party charges, loans and director fees;
• the names of the accountants, lawyers, trustees and banks who act for the family or group;
• the decisions coming up in the next 12 to 18 months: a sale, a move, a new structure, a distribution.

Then come conversations with the principal or the CFO, and with each existing adviser. The aim is to find out what each adviser has been asked to do, and what nobody has been asked to do.

Days 1 to 30: which UAE checks come first?

Some checks can’t wait for the full tax agenda because the deadlines and penalties are fixed in law.

• Registration. Every taxable person must register for corporate tax within the timeline the FTA sets (Article 51 of Federal Decree-Law No. 47 of 2022, the Corporate Tax Law). The penalty for a late registration application is AED 10,000 (Cabinet Decision No. 75 of 2023, as amended).
• Returns and payment. A return must be filed, and any tax paid, within nine months of the end of each tax period (Articles 48 and 53 of the Corporate Tax Law).
• Records. A taxable person must keep the records that support its returns for seven years after the end of the tax period (Article 56). Failing to keep the required records carries a penalty of AED 10,000, or AED 20,000 for a repeat within 24 months (Cabinet Decision No. 75 of 2023).
• E-invoicing. Businesses with revenue of AED 50 million or more had until 30 October 2026 to appoint an Accredited Service Provider and must go live by 1 January 2027; any that missed the date should appoint one now. Businesses below that figure must appoint one by 31 March 2027 and go live by 1 July 2027 (Ministerial Decision No. 244 of 2025, as amended by Ministerial Decision No. 66 of 2026).
• Foundations. A foundation, or a company wholly owned and controlled by one, whose application for transparent treatment has been approved files an annual confirmation within nine months of the end of each tax period (Federal Tax Authority Decision No. 5 of 2025, Article 10(1); FTA Family Foundations guide, June 2026).

If the review finds that a return already filed understated the tax, the Tax Procedures Law requires a voluntary disclosure (Article 10 of Federal Decree-Law No. 28 of 2022). Timing changes the cost. If the disclosure is made before the FTA gives notice of a tax audit, the penalty is 1% of the tax difference for each month. If it is made only after that notice, or not made at all, a fixed penalty of 15% of the tax difference applies on top of the monthly one (Cabinet Decision No. 75 of 2023, items 10 and 11). This is one reason the first month starts with the returns.

Days 31 to 60: what goes into your tax agenda?

Your tax agenda is a written view of the entities, countries, advisers and live decisions, with the open issues marked. For each entity it records:

• where it is resident, and on what basis;
• its UAE corporate tax status: taxable, exempt, transparent, Qualifying Free Zone Person or in a tax group;
• its CRS and FATCA classification;
• its related-party transactions and payments to owners and directors;
• the advisers who act for it and what each has been asked to do.

Related parties need care at this stage. Transactions between related parties must meet the arm’s length standard (Article 34 of the Corporate Tax Law), and payments to connected persons such as owners and directors are deductible only to the extent they reflect market value (Article 36). A taxable person with revenue of AED 200 million or more, or one that belongs to a multinational group with consolidated revenue of AED 3.15 billion or more, must keep a master file and a local file (Ministerial Decision No. 97 of 2023), and must produce them within 30 days if the FTA asks (Article 55). Below those thresholds, records supporting the arm’s length position are still needed, and the FTA can ask for them (Article 55(4); FTA Transfer Pricing guide). PBF’s transfer pricing team has written on the local file and the master file.

For families, the tax agenda also covers each person: where they are tax resident, on which test, and what evidence exists. Our guide to UAE tax residency for relocating families covers the tests.

Days 61 to 90: what does the action plan look like?

The action plan turns the open issues into work. Each line says what has to be resolved, the work required, who does it and by when. Some items stay with the head of tax, and others go to the accountant, the lawyer or a specialist, with a written brief that carries the facts from other countries.

A typical first plan mixes three kinds of item: fixing what is already wrong, such as a missing registration or an unpriced loan; preparing for decisions already in the diary; and putting the routines in place, such as one calendar for every entity and a positions log.

What does reporting look like after day 90?

Reports follow an agreed schedule, often quarterly. Each one covers filings made and due, open questions with tax authorities, decisions coming up and any change in law or residence that affects you. Between reports, the head of tax should hear about new decisions early enough to shape them.

If the FTA writes in that period, the head of tax coordinates the reply. If you disagree with an FTA decision, a reconsideration request has to be made, with reasons, within 40 business days of being notified (Article 29 of the Tax Procedures Law). Formal disputes usually need a separate specialist engagement, and PBF’s page on tax disputes explains how that work runs.

How Within runs the first 90 days

Within, by PBF, is fractional tax advisory: your tax team, within your business. A senior tax team works as part of your family office or business, alongside your accountants, lawyers and trustees, and we shape the first 90 days around your priorities. Before we start, we agree the initial work and what it will produce: your tax agenda, an agreed action plan and a reporting schedule, with your written mandate setting out the countries, entities and ongoing work covered. See how Within works.

Start by gathering the entity list, the last returns and any FTA letters, which is the first week’s reading.