This decision fundamentally shifts the exemption model for Qualifying Investment Funds (QIFs), moving away from strict ownership diversity thresholds to a framework based on investor-level income adjustments. For investors in QIFs and REITs with significant immovable property income, 80% of this income is included in their taxable income. It also introduces exemption conditions for Qualifying Limited Partnerships (QLPs) engaged in Investment Business that do not derive income from UAE immovable property. This decision repeals Cabinet Decision 81 of 2023 for tax periods commencing on or after January 1, 2025, introducing greater tax neutrality.