United Arab Emirates: Corporate Tax In The UAE Free Zones – Clarification On The Qualifying Income And Substance Requirements For The Qualifying Free Zone Persons

Introduction

On the 1^st of June 2023, provisions of the Federal Decree-Law No. 47 of 2022 – Taxation of Corporation and Businesses (further also as the 'UAE CT Law') entered into force and became an immanent part of the UAE tax landscape. As a result, the UAE has introduced corporate tax at the rate of 9% for most taxpayers.

On the first day of June 2023, the Cabinet and the Minister of Finance released for the public one of the most anticipated decisions regarding the corporate tax regime for the companies located in the UAE Free Zones¹.

The UAE CT Law introduced a category of taxpayers that can be subject to corporate tax at the reduced rate of 0% – the Qualifying Free Zone Persons (QFZPs).

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