Strategic advisory on the UAE corporate tax regime, qualifying free zone person status, transfer pricing, and tax group elections.
The introduction of UAE corporate tax at 9% on taxable income exceeding AED 375,000 has fundamentally altered the tax planning landscape for every UAE-based business. While the headline rate is competitive by global standards, the regime's complexity lies in its interaction with free zone structures, transfer pricing requirements, group relief provisions, and the qualifying free zone person (QFZP) exemption.
For free zone entities, the critical question is whether they qualify for the 0% rate on qualifying income. QFZP status requires meeting substance, revenue, and compliance conditions that demand careful analysis and ongoing monitoring. A failure to meet these conditions — even inadvertently — results in the entity being taxed at the standard 9% rate on all income.
Polaris provides strategic corporate tax advisory that integrates tax considerations with broader corporate structuring decisions. We work with clients to optimise their tax position within the full range of available structures across UAE, Cyprus, and Switzerland.
Answers drawn from the published rules of the UAE authorities and regulators. Each answer links to its official source. Last reviewed 25 October 2026.
The headline rate is 9%, charged on taxable income above AED 375,000; the portion up to and including AED 375,000 is taxed at 0%. Both figures are published by the Ministry of Finance under Federal Decree-Law No. 47 of 2022. The regime applies to financial years starting on or after 1 June 2023, so a company with a calendar-year financial year has been within scope since 1 January 2024. Taxable income starts from the accounting net profit in your financial statements and is then adjusted under the law. We review the adjustments, elections and reliefs available to you before the first return is prepared, so that the position you file is the one you intended.
Sources: Ministry of Finance — Corporate Tax FAQs; Federal Tax Authority — Corporate Tax FAQs (accessed 24 October 2026)
Only if it is a Qualifying Free Zone Person, and only on its Qualifying Income. The FTA's conditions are that the company maintains adequate substance in a free zone, derives Qualifying Income, has not elected to be taxed at the standard rate, complies with the arm's length principle and keeps transfer pricing documentation, prepares audited financial statements, and keeps non-qualifying revenue within the de minimis limit of the lower of AED 5 million or 5% of total revenue. Everything that is not Qualifying Income is taxed at 9%, and a Qualifying Free Zone Person does not receive the 0% band on the first AED 375,000. We test each revenue stream against the qualifying and excluded activity lists before you rely on the 0% rate.
Source: Federal Tax Authority — Basic Tax Information Bulletin – Free Zone Persons (accessed 24 October 2026)
It loses the 0% rate for five tax periods. The FTA states that a company which fails any condition, or elects into the standard regime, ceases to be a Qualifying Free Zone Person from the beginning of the tax period in which the failure occurs and for the four subsequent tax periods. During that time all of its taxable income is taxed under the standard rules at 9%. Because the de minimis test and the audit requirement are the conditions most often missed, we monitor them during the year rather than discovering a breach when the return is prepared.
Sources: Federal Tax Authority — Basic Tax Information Bulletin – Free Zone Persons; Ministry of Finance — Corporate Tax FAQs (accessed 24 October 2026)
Yes, if the conditions in Article 40 of Federal Decree-Law No. 47 of 2022 are met. The parent must be a UAE resident juridical person that holds, directly or indirectly, at least 95% of the subsidiary's share capital, 95% of its voting rights and 95% of its entitlement to profits and net assets. Neither company may be an Exempt Person or a Qualifying Free Zone Person, and both must share the same financial year and accounting standards. The group is then treated as a single taxable person, represented by the parent, which files one return for all members. We assess whether grouping actually helps you before applying to the FTA, because it also pools losses and consolidates the compliance burden.
Source: Federal Tax Authority — Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses (accessed 24 October 2026)
Small Business Relief lets a UAE resident taxable person with revenue of AED 3,000,000 or less in the current tax period and in every previous tax period elect to be treated as having no taxable income for that period. The threshold is set by Ministerial Decision No. 73 of 2023, which also limits the relief to tax periods ending on or before 31 December 2026. Qualifying Free Zone Persons and members of multinational groups cannot elect, no other reliefs or deductions are available in an elected period, and tax losses of that period cannot be carried forward. The election is made in the return. We model whether electing, or instead carrying losses forward, leaves you better off.
Sources: Federal Tax Authority — Ministerial Decision No. 73 of 2023 on Small Business Relief for the Purposes of Federal Decree-Law No. 47 of 2022; Federal Tax Authority — Corporate Tax Topics – Small Business Relief (accessed 24 October 2026)
For tax periods starting on or after 1 January 2025, Ministerial Decision No. 84 of 2025 requires audited financial statements from any taxable person (other than a tax group) with revenue exceeding AED 50,000,000 in the tax period, and from every Qualifying Free Zone Person regardless of revenue. A tax group must prepare audited special purpose financial statements in the form the FTA specifies. The earlier Ministerial Decision No. 82 of 2023 continues to apply to tax periods that began before 1 January 2025. Companies outside these categories may file on unaudited accounts, although the FTA's Tax Returns guide makes the financial statements a mandatory attachment to the return. We coordinate the audit timetable with the filing deadline so neither slips.
Sources: Federal Tax Authority — Ministerial Decision No. 84 of 2025 on Audited Financial Statements for the Purposes of Federal Decree-Law No. 47 of 2022; Federal Tax Authority — Corporate Tax Guide – Tax Returns (CTGTXR1) (accessed 24 October 2026)
Every taxable person must price related-party and connected-person transactions at arm's length, but the formal master file and local file are required only above the thresholds in Ministerial Decision No. 97 of 2023: revenue of AED 200,000,000 or more in the tax period, or membership of a multinational group with consolidated revenue of AED 3,150,000,000 or more. Where required, the files must be produced within 30 days of an FTA request. A Qualifying Free Zone Person must keep transfer pricing documentation as a condition of its 0% rate. Businesses electing Small Business Relief are not required to maintain the documentation. We prepare benchmarking and documentation proportionate to your size and risk.
Sources: Ministry of Finance — Ministerial Decision No. 97 of 2023 Requirements for Maintaining Transfer Pricing Documentation for the Purposes of Federal Decree-Law No. 47 of 2022; Federal Tax Authority — Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses (accessed 24 October 2026)
Only once business turnover is large enough. A natural person who conducts a business or business activity in the UAE becomes subject to corporate tax, and must register, when total revenue from that business exceeds AED 1 million in a calendar year; the FTA's registration page confirms the threshold. Salary, private investment income and real estate investment income are excluded from the calculation. Below the threshold there is no registration or filing obligation. Above it, the same 0% and 9% rates apply, and Small Business Relief may be elected while revenue stays at or below AED 3,000,000. We check whether a freelance permit holder has crossed the line and handle the registration if so.
Source: Federal Tax Authority — Corporate Tax Registration (service card) (accessed 24 October 2026)
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