United Arab Emirates

Caribbean citizenship-by-investment programmes have come under closer review over the last year as global standards on transparency tighten. The OECD has introduced new measures calling for deeper background checks and greater data sharing between governments to limit tax evasion and financial misconduct. In response, regional authorities are updating their approval systems and disclosure rules, which is already changing how investors prepare applications and the type of information they need to provide. The sections below explain how the OECD’s standards are taking shape, how Caribbean states are responding, and what investors should expect as the new framework comes into force. Understanding the OECD’s new standards The OECD’s reforms build on its Common Reporting Standard, a global framework designed to stop people from using multiple citizenships or accounts to hide wealth from tax authorities. The new rules go further, urging countries that offer citizenship-by-investment programmes to confirm the real tax residency of every applicant and share verified data when needed. This means governments will have to match their background checks with stricter financial disclosure and closer cooperation between agencies. For investors, the practical change lies in how information is gathered and verified. Source-of-wealth evidence will face greater scrutiny, and inconsistencies between jurisdictions will be flagged faster through automatic exchange systems. While the aim is to improve transparency across borders, the process places new responsibility on both applicants and local authorities to prove the integrity of each citizenship file. Caribbean programmes under review Caribbean governments have moved quickly to show cooperation with the OECD and the European Union. The five countries that run citizenship-by-investment programmes, St Kitts and Nevis, Dominica, Grenada, St Lucia and Antigua and Barbuda, signed a joint agreement earlier this year setting new standards for how their schemes are run. The framework includes a shared minimum investment level, tighter vetting procedures and greater exchange of applicant data with international partners. Some jurisdictions have already revised their rules or paused specific routes while they upgrade due diligence systems. St Kitts raised its minimum contribution to USD 250,000, while Dominica and Grenada introduced independent audits of their CBI units and additional layers of background screening. The aim is to keep these programmes credible and protect their visa-free access arrangements with the EU and the UK. These steps mark the first coordinated effort across the region to apply shared standards, giving the programmes a stronger footing with international partners. What this means for investors For investors, the reality is a slower, more detailed process as scrutiny deepens under the new framework. Background checks that once took weeks may now take months as governments verify financial records, source of wealth and tax residency with greater precision. Applicants will need to prepare more detailed documentation and expect follow-up questions where information doesn’t line up across jurisdictions. The process is starting to resemble enhanced due diligence in financial services, with clearer templates for wealth verification and third-party data checks. This makes consistency more likely but also means applicants have to plan carefully. The new reporting system also limits the privacy these programmes once offered. Tax authorities now share information automatically, so each file needs to present an accurate picture of an investor’s income, assets and residence status. Gaps or inconsistencies can slow approval or trigger further review. Fees and minimum investment levels may also increase as governments cover the higher costs of compliance. Investors who prepare early, keep their records organised and work with experienced advisors will find the process smoother and less open to delay. Outlook for 2025 and beyond Over the coming year, the Caribbean programmes are expected to settle into a more uniform structure as the OECD standards take hold. Processing may stay slower, but governments are likely to balance stricter checks with predictable procedures once systems mature. For applicants with clear financial records and well-documented sources of wealth, legitimate routes will remain open. These programmes continue to serve investors who value global mobility and portfolio diversification, though the path now demands more preparation and transparency. Demand is expected to stay steady, with greater interest in jurisdictions that show strong compliance and stable international relationships. As reforms bed in, confidence will depend less on speed and more on the quality of compliance behind each application, shaping how both governments and investors approach citizenship planning in the years ahead. How can The Knightsbridge Group help? The Knightsbridge Group supports investors through every stage of the citizenship and residency process, from preparing financial records to coordinating with programme authorities and international partners. Our experience across multiple jurisdictions means clients receive practical guidance that fits both current OECD standards and local due diligence rules. To discuss your plans or review an existing application, contact [email protected].  

Entering into a hotel management agreement (“HMA”) in Dubai is a high-stakes decision for any property owner. The emirate’s hospitality sector operates under a complex regulatory framework overseen by multiple authorities, including the Dubai Department of Economy & Tourism (“DET”), Dubai Civil Defence, the UAE Federal Tax Authority, and various federal labour and data-protection regulators. While hotel managers oversee day-to-day operations, the ultimate responsibility for legal and regulatory compliance almost always rests with the property owner. 1. Licensing and Regulatory Compliance One of the most significant challenges for owners lies in licensing and operational compliance. Hotel operating licences and related permits are typically issued in the owner’s name, which makes the owner directly liable for renewals, record-keeping, and any violations—even when the management company is at fault. To mitigate this exposure, the HMA should: Acknowledge the owner as the licence holder; Obligate the manager to comply with all operational regulations and filing deadlines; Require the prompt provision of supporting documents; and Include robust indemnities and audit rights so that any fines caused by the manager’s actions can be recovered. 2. Financial and Tax Compliance Financial compliance presents another layer of complexity. Hotel managers typically collect the Tourism Dirham fee, municipality service charges, and VAT on behalf of the owner. However, it is the owner who remains the taxable person responsible for filings and remittances. Any misreporting can result in significant penalties. An effective HMA should therefore: Require detailed reconciliations and regular tax reports; Include warranties regarding the manager’s accounting systems and tax codes; Provide indemnities and clear audit rights to ensure transparency and accountability. 3. Health, Safety, and Employment Obligations Dubai enforces strict health and safety standards under the UAE Fire and Life Safety Code and other municipal regulations. Violations can lead to fines, closures, or costly remediation orders. The agreement should: Assign daily safety compliance duties to the manager; Mandate comprehensive record-keeping; and Grant the owner step-in rights and cost-recovery mechanisms in cases of manager negligence. Employment compliance is equally important. If the owner is the employer of the hotel workforce, they are liable for payroll, visa sponsorship, and end-of-service gratuities. The HMA should  clearly specify: The employer of record; The manager’s obligations under Federal Decree-Law No. 33 of 2021 and MoHRE regulations; and Indemnities covering any breach of employment laws. 4. Financial Reporting and Insurance Transparent and consistent financial reporting is fundamental to every successful HMA. Without it, owners risk revenue discrepancies, tax errors, and operational disputes. To prevent these risks, the HMA should: Mandate standardized monthly and annual financial reports; Grant the owner direct access to management and accounting systems; Require independent audits; and Include data migration and system integration provisions to ensure business continuity upon termination. Insurance provisions also warrant careful drafting. The owner should be: Named as an additional insured on all policies; Provided with proof of renewal annually; and Protected by clauses excluding liability caps for regulatory fines, gross negligence, and wilful misconduct. 5. Ownership and Management Changes Changes in ownership or management can trigger regulatory complications. Transfers of ownership or control often require prior approval from DET or other authorities. Failure to secure such approval can affect the status of the property’s operating licences. To manage these scenarios, the HMA should: Require written notice of any change; and Mandate cooperation in obtaining regulatory approvals. 6. Data Protection and Cybersecurity Hotels manage large volumes of personal and financial data, making compliance with privacy laws critical. HMAs must adhere to the UAE Personal Data Protection Law (Federal Decree-Law No. 45 of 2021) and, where applicable, the DIFC Data Protection Law. Key data-protection provisions should include: A data-processing addendum defining roles, transfer restrictions, and breach-response procedures; Compliance with global payment-card standards (PCI-DSS); and Integration of anti-money-laundering (AML) and counter-terrorist-financing (CTF) obligations under Federal Decree-Law No. 20 of 2018, supported by cyber-insurance coverage and immediate breach-notification duties. 7. Performance Tests and Capital Expenditure Performance tests are critical owner protections. Without objective benchmarks—such as Revenue per Available Room (RevPAR) or Gross Operating Profit (GOP)—owners risk being locked into underperforming management arrangements. An HMA should therefore establish: Measurable performance metrics; Defined cure periods and termination rights; and Step-in rights for the owner in cases of significant non-compliance. For capital expenditure (capex), the agreement should: Distinguish routine maintenance from capital projects; Create a Furniture, Fixtures & Equipment (FF&E) reserve (typically 3–5% of gross revenue); and Require annual capex plans subject to owner approval. 8. Governing Law and Dispute Resolution The governing law and dispute-resolution mechanism are key strategic considerations. Many owners choose UAE law and the jurisdiction of the Dubai Courts, while others prefer arbitration—for instance, under the Dubai International Arbitration Centre (DIAC) or DIFC-LCIA—to ensure neutrality and enforceability. Conclusion HMAs in Dubai require more than sound commercial terms—they demand a carefully structured legal framework that anticipates regulatory complexity and allocates risk with precision. Owners who put in place strong legal protections, including indemnities, audit rights, performance standards, and compliance obligations, position themselves to safeguard their investment and maintain operational excellence in one of the world’s most competitive hospitality markets. Authors: Suzanne Hashem, Legal Director and Khaled Abu Orabi, Senior Associate.

Dubai has unveiled a comprehensive development strategy aimed at positioning the city as the world’s most liveable and healthy urban environment by 2033. The plan includes sweeping initiatives across green infrastructure, education, aviation, healthcare, sports, and financial governance, reflecting Dubai’s commitment to long-term sustainability, wellbeing, and economic resilience. The new measures were approved by The Executive Council of Dubai, chaired by His Highness Sheikh Hamdan bin Mohammed bin Rashid Al Maktoum, Crown Prince of Dubai, as part of the broader Dubai Plan 2033 under the vision of His Highness Sheikh Mohammed bin Rashid Al Maktoum, Vice President and Prime Minister of the UAE and Ruler of Dubai. 1. Expanding Green Spaces: 310 New Parks and 800 Public Green Projects A central pillar of the plan is the Public Parks and Greenery Strategy, which will deliver more than 800 new urban green projects, including: 310 new public parks Upgrades to 322 existing parks 120 additional open recreational spaces 14 smart-technology-led sustainability initiatives The city also plans to triple its total number of trees and expand green areas to 187 square kilometres, ensuring that 80% of residents will live within a five-minute walk of a neighbourhood park. All irrigation systems will operate on 100% recycled water, reinforcing Dubai’s sustainability commitments. 2. Aviation Expansion: 15,000 New Jobs and Global Talent Development As Dubai continues its rise as a global aviation powerhouse – particularly with the expansion of Al Maktoum International Airport – the Aviation Talent 33 programme will: Create 15,000 new skilled jobs Provide 4,000 specialised training and upskilling programmes Establish 30 new international aviation partnerships Support the integration of Emirati talent into strategic sector roles This aligns with Dubai’s broader goals to double the size of its economy, attract AED 650 billion (USD 177 billion) in foreign investment, and increase Emirati participation in private-sector growth. 3. Strengthening Education: 60 New High-Quality Affordable Schools Dubai has approved a new Affordable Schools Policy designed to increase access to high-quality education while reducing cost barriers for families. The initiative will result in: 60 new affordable schools by 2033 120,000 new classroom seats Incentives for private investors, including reduced land leases and lower licensing fees The move supports the Dubai Education Strategy 2033, which aims to position Dubai among the top 10 cities globally for education outcomes. 4. Advancing Preventative Healthcare A new healthcare programme focusing on early medical detection and preventative care aims to increase life expectancy and reduce chronic disease rates. Key targets include: 40% increase in early colon cancer screening 50% expansion in vaccination coverage Appointment waiting times reduced to 7 days or less 90%+ patient satisfaction rates Sheikh Hamdan reaffirmed that early health intervention is both a personal and national priority, calling it “an investment in the future wellbeing of society.” 5. Turning Dubai into a Global Sports Capital Under the Sports Sector Strategy 2033, Dubai will expand support for: Professional and youth athletes International sports events Investment and development in 17 priority sports The programme includes 75 initiatives to position Dubai as a leading global sports hub, enhancing community wellbeing and international cultural engagement. 6. Reinforcing Financial Stability and Business Confidence A new Financial Restructuring and Insolvency Court will establish a specialised legal framework for restructuring, insolvency, and corporate recovery. This strengthens Dubai’s position as a top-tier international financial centre by: Protecting creditor and investor rights Ensuring business continuity Encouraging efficient recovery instead of forced liquidation A Unified Vision for the Next Decade Commenting on the initiatives, Sheikh Hamdan said: “We are building the world’s most liveable city – one that balances nature, innovation, health, and opportunity for future generations.” Knightsbridge Group Commentary Dubai’s 2033 initiatives signal strong, forward-looking policy stability, supporting long-term investment across: Real estate and development Education and healthcare infrastructure Aviation and logistics Sports, hospitality, and leisure sectors For international investors, families, and companies, the strategy reinforces Dubai’s position as a secure, growth-oriented environment for living, building, and investing. Knightsbridge Group continues to assist clients in navigating company formation, residency planning, investment structuring, and market entry as Dubai accelerates into its next phase of global leadership.

BSA LAW is pleased to announce a significant success achieved by its Tax practice, led by Partner and Head of Tax, Shamma Al Falahi. The Firm’s client had previously sought relief from value-added tax (VAT) penalties under the regime of Federal Decree‑Law No. (8) of 2017 on VAT and Federal Decree‑Law No. (7) of 2017 on Tax Procedures after multiple prior attempts had been unsuccessful. Upon engagement, BSA LAW conducted an in-depth review of the client’s VAT position and procedural history and then engaged in a comprehensive legal analysis and constructive dialogue with the relevant tax authorities. As a result of this approach, the VAT penalties were fully waived in accordance with the applicable legal provisions. This outcome underscores the value of procedural accuracy, diligent representation and deep tax-law expertise in achieving fair results within the UAE’s transparent and established tax-framework. “At BSA LAW, we remain committed to upholding our clients’ rights with precision, professionalism and integrity,” said Shamma Al Falahi. “This matter exemplifies how focused tax and regulatory advice can lead to meaningful relief.”