Two Pillars Advisory / Insights

UAE Corporate Tax 2026: Complete Guide to Free Zone Exemptions

Understand the UAE's 9% corporate tax regime, qualifying free zone income exemptions, transfer pricing rules, and compliance deadlines.

UAE Corporate Tax: The Basics

The UAE introduced a federal corporate tax effective from June 1, 2023, at a standard rate of 9% on taxable profits exceeding AED 375,000. Profits up to AED 375,000 are taxed at 0%, making the UAE one of the most competitive tax jurisdictions globally.


Who Is Subject to UAE Corporate Tax?

Entity TypeTaxable?Notes
UAE mainland companiesYes9% on profits > AED 375,000
Free zone companiesConditionally0% on qualifying income; 9% on non-qualifying
Foreign companies with UAE PEYesOn UAE-sourced income
Individuals (business income)ConditionallyOnly if turnover > AED 1,000,000
Government entitiesNoExempt
Extractive industriesNoSubject to emirate-level taxation

Free Zone Tax Exemptions: Qualifying Income

Free zone companies can benefit from the 0% corporate tax rate on Qualifying Income if they meet the following conditions:

Conditions for Qualifying Free Zone Person (QFZP)

  • Maintain adequate substance in the UAE (employees, expenditure, assets)
  • Derive qualifying income (see below)
  • Have not elected to be subject to standard corporate tax
  • Comply with transfer pricing documentation requirements
  • Prepare audited financial statements

What Is Qualifying Income?

Income TypeQualifies for 0%?
Transactions with other free zone personsSubject to beneficial-recipient, activity and other qualifying-income conditions
Transactions with non-free-zone persons (mainland UAE or foreign)Specified Qualifying Activities may qualify; customer location alone does not determine the rate
Income from certain qualifying activities✅ Yes
Passive income (interest, royalties) from mainland❌ No (9%)
Income from immovable property in UAE❌ No (9%)
Income from excluded activities❌ No (9%)

Qualifying Activities

  • Manufacturing of goods
  • Processing of goods
  • Holding shares and securities
  • Treasury and financing services to related parties
  • Reinsurance
  • Fund management
  • Wealth and investment management
  • Headquarters services to related parties
  • Logistics services
  • Distribution within a designated zone

Excluded Activities

  • Banking (regulated by Central Bank)
  • Insurance (regulated by CBUAE)
  • Finance and leasing (regulated activities)
  • Activities involving natural persons (retail, personal services)

Corporate Tax Rates Summary

Taxable Income BracketRate
AED 0 - AED 375,0000%
Above AED 375,0009%
Qualifying Free Zone Income0%
Non-Qualifying Free Zone Income9%
Large multinationals (revenue > EUR 750M)15% (Pillar Two)

Transfer Pricing Rules

The UAE follows OECD Transfer Pricing Guidelines:

  • Transactions with related parties must be at arm's length
  • Maintain a Master File and Local File if applicable
  • Country-by-Country Reporting for groups with consolidated revenue > AED 3.15 billion
  • Penalties for non-compliance: AED 10,000 - AED 50,000+

Key Compliance Deadlines

ObligationDeadline
Corporate Tax RegistrationWithin specified period from incorporation
Tax Return Filing9 months from end of tax period
Payment of Tax9 months from end of tax period
Transfer Pricing DocumentationMaintain contemporaneously

Exemptions and Reliefs

Small Business Relief

  • Available for resident persons with revenue ≤ AED 3,000,000
  • Treated as having no taxable income
  • Available by election to eligible resident persons for tax periods beginning on or after 1 June 2023 and ending on or before 31 December 2026, subject to the AED 3 million revenue test for the relevant and previous tax periods and statutory exclusions

Group Relief

  • 100% tax losses can be transferred between group companies
  • Companies must be 75%+ commonly owned
  • Both must be UAE resident juridical persons

Restructuring Relief

  • Business restructuring transactions can qualify for relief
  • Must meet specific conditions regarding continuity of ownership

Practical Examples

Example 1: Free Zone Transactions

A transaction with a free zone customer is not automatically Qualifying Income. Assess the activity, beneficial recipient, exclusions and all QFZP conditions before applying a 0% rate.

Example 2: Standard-Regime Company

Assume a company is subject to the standard UAE Corporate Tax regime, not QFZP treatment, and has AED 1,500,000 of taxable profit after applicable adjustments. With no other reliefs, the standard calculation is:

Tax Calculation:

  • Taxable profit: AED 1,500,000
  • Tax-free threshold: AED 375,000
  • Taxable amount: AED 1,125,000
  • Tax payable: AED 101,250

Example 3: Mixed Revenue and QFZP Eligibility

Assume AED 3,000,000 of relevant revenue includes AED 1,000,000 of non-qualifying revenue. The de minimis limit is the lower of 5% of relevant revenue or AED 5,000,000: here, AED 150,000. AED 1,000,000 exceeds that limit, so the example cannot retain QFZP treatment on a simple income split. Review loss-of-status rules with a qualified tax professional. There is no proportional AED 375,000 allowance for a QFZP’s income taxed at 9%.


How Two Pillars Advisory Can Help

  • Tax-Efficient Structuring: Choose the right jurisdiction to minimize tax exposure
  • Free Zone Selection: Identify zones with optimal qualifying income potential
  • Compliance Setup: Ensure proper registration, filing, and documentation
  • Transfer Pricing: Arm's length documentation and master/local file preparation
  • Ongoing Advisory: Annual compliance reviews and regulatory updates

Important Disclaimer

Two Pillars Advisory FZCO is an independent corporate services consultancy. We are not a tax advisory firm and do not provide tax advice. This article is for general informational purposes only. The UAE corporate tax regime is complex and subject to change. Always consult a qualified tax advisor registered with the UAE Ministry of Finance for specific guidance applicable to your business.


Need help structuring your UAE business for tax efficiency? Contact Two Pillars Advisory for a free consultation.

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