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UAE Corporate Tax — QFZP — 2026

UAE Corporate Tax & Free Zone QFZP Guide

Current guide to Qualifying Free Zone Person rules, Qualifying Income, Non-Free Zone transactions, Excluded Activities, the de minimis test, transfer pricing, financial statements and 2026 FTA compliance.

Current QFZP legal framework

The UAE Corporate Tax framework is established by Federal Decree-Law No. 47 of 2022. The current QFZP Qualifying Income framework is principally based on Cabinet Decision No. 100 of 2023, together with the Ministerial Decisions defining current Qualifying Activities, Excluded Activities and related calculations.

The current FTA legislation database also contains Ministerial Decision No. 229 of 2025 on Qualifying Activities and Excluded Activities and Ministerial Decision No. 84 of 2025 concerning audited Financial Statements for Corporate Tax purposes.

In addition, FTA Decision No. 6 of 2026 was issued on 2 June 2026 and published on 14 July 2026 to establish additional procedures for QFZP compliance.

0%
QFZP rate on Qualifying Income.
9%
Generally applies to Taxable Income that does not qualify for the QFZP 0% treatment.
5%
Percentage limit under the de minimis test.
AED 5M
Alternative de minimis ceiling, with the lower-of test.

Understand the QFZP categories

Qualifying Income

Applicable rate0% Corporate Tax
Income / activityIncome that falls within the current Qualifying Income rules, including income from specified Qualifying Activities with Free Zone and Non-Free Zone persons where the statutory conditions are satisfied and the activity is not an Excluded Activity.
ComplianceQFZP conditions must be satisfied, including adequate substance in the UAE Free Zone, Qualifying Income, arm’s-length compliance, required transfer-pricing records, audited Financial Statements where required, and the de minimis condition.
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Qualifying Income: mainland transactions are not automatically excluded

A transaction with a UAE mainland or other Non-Free Zone Person is not automatically non-qualifying.

Cabinet Decision No. 100 of 2023 provides that Qualifying Income can include income derived from transactions with a Non-Free Zone Person where the income relates to a Qualifying Activity that is not an Excluded Activity and the statutory conditions are satisfied.

TransactionAutomatic result?Correct approach
Sale to another Free Zone PersonNo automatic 0%.Check the Beneficial Recipient condition and whether the activity is qualifying and not excluded.
Sale to UAE mainland / Non-Free Zone customerNot automatically 9%.Income from a Non-Free Zone Person can qualify where the current Qualifying Activity rules permit it and the other conditions are satisfied.
Excluded ActivityNot QFZP 0%.Check the current Excluded Activities list and applicable Corporate Tax treatment.
Immovable propertySpecial rules apply.Analyse the property type, location, customer status and whether the income falls within the specific QFZP provisions.

QFZP conditions

Maintain adequate substance in the UAE Free Zone.
Derive Qualifying Income under the current legislation.
Comply with the arm’s-length principle for relevant related-party and permanent-establishment transactions.
Maintain required transfer-pricing documentation.
Maintain audited Financial Statements where required by the QFZP and applicable Corporate Tax rules.
Satisfy the current de minimis condition.
Do not elect to be subject to the standard Corporate Tax rules where that election would prevent QFZP treatment.

What does NOT create QFZP status by itself?

Simply having a Free Zone trade licence.
Having 100% foreign ownership.
Having no mainland customers.
Calling the company "tax-free" in its marketing.
Opening an EmaraTax account without satisfying the statutory conditions.
Preparing an audit without satisfying the other QFZP conditions.
Staying under AED 5 million of non-qualifying Revenue without applying the full de minimis calculation.

De Minimis Rule — 5% or AED 5 million, whichever is lower

A QFZP satisfies the de minimis condition where its non-qualifying Revenue does not exceed 5% of total Revenue or AED 5 million, whichever is lower.

Total Revenue5% of RevenueApplicable ceiling
AED 2,000,000AED 100,000AED 100,000
AED 10,000,000AED 500,000AED 500,000
AED 100,000,000AED 5,000,000AED 5,000,000
AED 200,000,000AED 10,000,000AED 5,000,000

What happens when the de minimis condition is breached?

A failure to satisfy a QFZP condition can cause the person to cease being a QFZP for the relevant Tax Period and subsequent Tax Periods as prescribed by the Corporate Tax legislation.

ScenarioConsequence
De minimis condition satisfiedQFZP condition can continue to be satisfied, assuming all other requirements are also met.
De minimis condition exceededQFZP status can be lost under the statutory cessation rules.
QFZP status lostThe entity can become subject to the standard Corporate Tax regime at 9% on its Taxable Income, subject to the applicable cessation and transitional provisions.

Qualifying Activities and Excluded Activities

The activity list is defined by current legislation, including Ministerial Decision No. 229 of 2025 on Qualifying Activities and Excluded Activities.

Activity areaCurrent treatment
ManufacturingCan fall within the qualifying-activity framework subject to the current Ministerial Decision and all QFZP conditions.
Qualifying distributionSubject to the current statutory definition and the specific distribution conditions, including applicable Designated Zone rules.
Holding investmentsCertain holding of shares and securities for investment purposes can be a Qualifying Activity, subject to the current rules.
Headquarters / related servicesCertain headquarters and related-party services can qualify where they satisfy the applicable statutory definition.
LogisticsCertain logistics services can be qualifying activities, but the precise current definition must be checked.
Fund / investment managementSpecific financial and investment-management activities can qualify subject to the current regulatory definitions and conditions.
Excluded activitiesIncome from Excluded Activities does not receive 0% merely because the company is a Free Zone Person.

Transfer pricing and financial statements

RequirementCurrent position
Arm’s-length principleQFZPs must comply with arm’s-length requirements for relevant related-party and permanent-establishment arrangements.
Transfer Pricing documentationRequired where the Corporate Tax rules require it. Satisfying the QFZP condition should not be described merely as a generic "keep TP documents" statement without considering the applicable thresholds and documentation rules.
Financial StatementsQFZP rules include audited Financial Statement requirements, while Ministerial Decision No. 84 of 2025 contains current rules concerning audited Financial Statements for Corporate Tax purposes more broadly.
AuditThe exact audit obligation should be checked against the current statutory category, the QFZP requirements and the current Financial Statement decision.

2026 QFZP compliance update

FTA Decision No. 6 of 2026 is now part of the current compliance framework. The FTA's official legislation database states that the decision was issued on 2 June 2026 and published on 14 July 2026.

2026 sourceSignificance
FTA Decision No. 6 of 2026Determines additional procedures for QFZP compliance.
Ministerial Decision No. 229 of 2025Current decision concerning Qualifying Activities and Excluded Activities.
Ministerial Decision No. 84 of 2025Current decision concerning audited Financial Statements for Corporate Tax purposes.
Cabinet Decision No. 100 of 2023Core Cabinet framework identifying Qualifying Income for QFZPs.

Frequently Asked Questions

No. A Free Zone entity must satisfy the conditions for Qualifying Free Zone Person status and the 0% rate applies to Qualifying Income. Taxable Income that does not qualify for the QFZP treatment is generally subject to 9%. Free Zone incorporation alone does not make all income taxable at 0%.

The current de minimis test is satisfied when non-qualifying Revenue does not exceed 5% of the Qualifying Free Zone Person’s total Revenue or AED 5 million, whichever is lower. The detailed calculation has special rules concerning which revenue is included or disregarded.

Yes. It is incorrect to say that every transaction with a UAE mainland or other Non-Free Zone Person is automatically non-qualifying. Cabinet Decision No. 100 of 2023 allows certain income from Non-Free Zone Persons where it arises from a Qualifying Activity that is not an Excluded Activity and the other statutory conditions are satisfied.

The QFZP framework is based on satisfying the statutory conditions. A Free Zone Person that satisfies the conditions is treated as a QFZP unless it elects to be subject to the standard Corporate Tax rules. Therefore, it is not accurate to describe QFZP treatment simply as an optional EmaraTax checkbox that creates eligibility.

Audited Financial Statements form part of the QFZP conditions, and separate Corporate Tax legislation governs which Taxable Persons must prepare and maintain audited Financial Statements. The exact obligation must therefore be checked under the current QFZP rules and Ministerial Decision No. 84 of 2025 rather than stating that every Free Zone company automatically has an identical audit requirement.

FTA Decision No. 6 of 2026 introduced additional procedures for QFZP compliance. It was issued on 2 June 2026 and published on 14 July 2026. The current QFZP framework should therefore be checked against this decision together with Cabinet Decision No. 100 of 2023 and the current Ministerial Decisions on Qualifying and Excluded Activities.
2026 tax-reference noteQFZP status requires continuing compliance

The 0% QFZP treatment should not be presented as a permanent Free Zone tax exemption. The entity must continue to satisfy the applicable Corporate Tax conditions and the current Qualifying Income, Qualifying Activity, Excluded Activity, substance, transfer-pricing, financial-statement and de minimis requirements.