Home/UAE/Corporate Tax Qfzp Qualified Free Zone Person Guide
UAE QFZP — 2026

UAE Corporate Tax QFZP (0% Free Zone) Guide

Current guide to Qualifying Free Zone Person status, Qualifying Income, the de minimis test, mainland transactions, audited Financial Statements and the latest 2026 QFZP rules.

QFZP is a status, not simply a Free Zone licence

A Free Zone company does not automatically receive 0% Corporate Tax. The FTA states that a Free Zone entity must satisfy the statutory conditions to be treated as a Qualifying Free Zone Person.

The current framework requires, among other things, adequate UAE substance, Qualifying Income, transfer-pricing compliance and documentation, the applicable audited Financial Statement requirement, compliance with the de minimis condition and no election to be taxed under the standard Corporate Tax regime.

0%
On Qualifying Income for a valid QFZP.
9%
Generally on Taxable Income that is not Qualifying Income.
5%
One side of the de minimis lower-of test.
AED 5M
The other side of the de minimis lower-of test.

QFZP De Minimis Screening Calculator

Enter the relevant total Revenue and non-qualifying Revenue. The calculator applies the simple mathematical lower-of test. The actual tax return calculation must first apply the statutory Revenue exclusions required by the QFZP rules.

5% of Revenue
AED 500,000
Applicable Ceiling
AED 500,000
Actual Percentage
3.00%

This screening tool cannot determine QFZP status because de minimis is only one of the QFZP conditions.

The complete QFZP condition checklist

Qualifying Income under Cabinet Decision No. 100 of 2023

Cabinet Decision No. 100 of 2023 replaced the earlier Cabinet Decision No. 55 of 2023 and provides the current core framework for identifying Qualifying Income. It expressly allows certain income from Free Zone Persons and certain income from Non-Free Zone Persons where the relevant Qualifying Activity conditions are satisfied.

Source of incomeQFZP treatment
Transactions with Free Zone PersonsCan be Qualifying Income where the Free Zone Person is the Beneficial Recipient and the income does not arise from an Excluded Activity.
Transactions with Non-Free Zone PersonsCan be Qualifying Income where the income relates to a Qualifying Activity that is not an Excluded Activity and the other statutory conditions are satisfied.
Qualifying Intellectual PropertySubject to the specific IP nexus and calculation rules.
Other incomeCan qualify subject to the de minimis rules and the current Cabinet / Ministerial Decisions.

De Minimis Rule — the lower-of test

The rule is satisfied where non-qualifying Revenue does not exceed the lower of 5% of total Revenue or AED 5 million.

Relevant Revenue5% amountLower-of 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 500,000,000AED 25,000,000AED 5,000,000

Revenue used in the de minimis calculation is not simply every accounting revenue line

The FTA's Free Zone Persons guide explains that Revenue for the de minimis calculation must be adjusted. Among other items, the calculation disregards Revenue attributable to a Foreign Permanent Establishment, a Domestic Permanent Establishment, specified immovable property income and certain intellectual property income.

Revenue categoryGeneral de minimis treatment
Foreign Permanent Establishment revenueDisregarded in the relevant de minimis calculation where attributable to the Foreign PE.
Domestic Permanent Establishment revenueDisregarded from the relevant total Revenue calculation where attributable to the Domestic PE.
Certain Free Zone immovable-property revenueSubject to the specific statutory exclusions and commercial-property rules.
Qualifying / non-qualifying business RevenueSegregated according to the applicable Qualifying Activity, Excluded Activity, Beneficial Recipient and Non-Free Zone rules.

The FTA provides worked examples showing why the accounting "total revenue" figure cannot simply be copied into the de minimis denominator.

Qualifying Income can include certain mainland transactions

A major misconception is that QFZP 0% applies only to customers in Free Zones. Cabinet Decision No. 100 expressly states that income from a Non-Free Zone Person can be Qualifying Income when it relates to Qualifying Activities that are not Excluded Activities and the other conditions are met.

ScenarioAutomatic result?Correct analysis
Free Zone Person customerNo.Check Beneficial Recipient and Excluded Activity requirements.
Mainland / Non-Free Zone customerNo.Certain Qualifying Activities can produce Qualifying Income even when the counterparty is a Non-Free Zone Person.
Excluded ActivityNo.The income does not receive the QFZP 0% treatment merely because the company is in a Free Zone.

Current QFZP compliance requirements

RequirementCurrent treatment
Adequate substanceQFZP must maintain adequate substance in the UAE Free Zone.
Qualifying IncomeThe entity must derive Qualifying Income under the current Cabinet and Ministerial Decisions.
Transfer pricingApplicable arm's-length and transfer-pricing requirements and documentation must be satisfied.
Audited Financial StatementsQFZPs are among the categories required to prepare and maintain audited Financial Statements under the current Corporate Tax framework.
De minimisNon-qualifying Revenue must remain within the lower-of 5% / AED 5 million test after the statutory adjustments.
Standard-rate electionA Free Zone Person can elect to be taxed under the standard Corporate Tax rules and rates, which means it does not obtain QFZP 0% treatment for the applicable period and prescribed subsequent periods.

Losing QFZP status

If a QFZP fails a QFZP condition or elects to be taxed under the standard Corporate Tax rules and rates, it ceases to be a QFZP from the beginning of the relevant Tax Period and for the four subsequent Tax Periods. In other words, the affected period plus four subsequent periods form the five-Tax-Period consequence described in the legislation.

EventQFZP consequence
Condition fails in Tax Period 2026QFZP status ceases from the beginning of 2026 and for the four subsequent Tax Periods, subject to the applicable rules.
Standard-rate electionQFZP treatment ceases under the election rules for the election period and prescribed subsequent period.
After the cessation periodThe entity may reassess QFZP eligibility under the applicable legislation.

Small Business Relief and QFZP

2026 QFZP developments

Current sourceWhy it matters
Cabinet Decision No. 100 of 2023Current core Qualifying Income framework; it replaced the earlier Cabinet Decision No. 55 of 2023.
Ministerial Decision No. 265 of 2023Contains the de minimis and Qualifying Intellectual Property provisions; it also repealed Ministerial Decision No. 139 of 2023.
Ministerial Decision No. 229 of 2025Current decision concerning Qualifying Activities and Excluded Activities; activity classifications should be checked against the current decision.
Ministerial Decision No. 84 of 2025Current framework for audited Financial Statements under the Corporate Tax regime.
FTA Decision No. 6 of 2026Additional procedures for QFZP compliance, issued 2 June 2026 and published 14 July 2026.

Frequently Asked Questions

A QFZP is a Free Zone Person that satisfies the statutory QFZP conditions, including adequate substance in the UAE, deriving Qualifying Income, complying with transfer-pricing rules and documentation, meeting the applicable audited Financial Statement requirement, satisfying the de minimis condition, and not electing to be subject to the standard Corporate Tax rules. QFZP treatment allows 0% on Qualifying Income and generally 9% on Taxable Income that is not Qualifying Income.

The non-qualifying Revenue of a QFZP must not exceed the lower of 5% of the relevant total Revenue or AED 5 million in the Tax Period. The calculation is not simply a percentage of every accounting revenue line because the QFZP rules specify Revenue that must be included or disregarded for this test.

Yes, potentially. Cabinet Decision No. 100 of 2023 provides that income from a Non-Free Zone Person can constitute Qualifying Income where it relates to a Qualifying Activity that is not an Excluded Activity and the other statutory conditions are satisfied. Therefore, "mainland customer = automatically 9%" is incorrect.

Yes. A QFZP is one of the categories required to prepare and maintain audited Financial Statements under the Corporate Tax framework. The exact accounting and audit requirements should be checked against the current Corporate Tax Law and the current Ministerial Decisions on audited Financial Statements rather than reducing the rule to a generic "every Free Zone company must have an IFRS audit."

If a Free Zone Person fails a QFZP condition or elects to be subject to the standard Corporate Tax rules, it ceases to be a QFZP from the beginning of the relevant Tax Period and for the four subsequent Tax Periods. The entity then falls under the standard Corporate Tax rules and rates applicable to it.

A Qualifying Free Zone Person cannot elect Small Business Relief. In addition, current QFZP compliance must be checked against the updated legislative framework, including FTA Decision No. 6 of 2026, which introduced additional QFZP compliance procedures.
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2026 tax-reference noteQFZP status requires continuing compliance

The QFZP 0% treatment is not a blanket Free Zone tax exemption. It depends on continuing compliance with the applicable Corporate Tax Law, Cabinet Decisions, Ministerial Decisions and FTA procedures. This page provides a screening guide, not a tax-return determination.