This decision revises the criteria for a non-resident person's tax nexus in the UAE. A nexus is created if the non-resident derives income from immovable property in the State. It expands the definition to include non-resident investors in Qualifying Investment Funds whose income is adjusted under Cabinet Decision No. 34 of 2025. This establishes a nexus for foreign investors in certain UAE investment funds, mandating their registration for Corporate Tax. The anti-abuse rule against artificial property transfers is maintained.