
A comprehensive guide to the UAE corporate tax framework under Federal Decree-Law No. 47 of 2022 as amended by Decree-Law No. 28 of 2025 — covering rates, exemptions, filing obligations, and penalties.
The United Arab Emirates introduced its federal corporate tax regime effective for financial years starting on or after 1 June 2023, marking a historic shift in the country's fiscal landscape. Governed by Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses, and subsequently amended by Federal Decree-Law No. 28 of 2025, the framework positions the UAE as a transparent, internationally compliant jurisdiction while preserving its competitive edge as a global business hub.
Whether you are an established mainland company, a free zone entity, or an entrepreneur planning to enter the UAE market, understanding the corporate tax framework is essential for compliance and strategic planning. This guide breaks down every critical aspect of the law as it stands in 2026.
The UAE corporate tax is a federal tax levied on the net profits of businesses operating in the country. It was introduced as part of the UAE's broader strategy to diversify revenue sources, align with international tax standards, and meet commitments under the OECD Base Erosion and Profit Shifting (BEPS) Inclusive Framework.
The tax applies uniformly across all seven emirates. There is no separate emirate-level corporate tax.
Applicable to financial years starting on or after 1 June 2023. Businesses with a January–December financial year became subject from 1 January 2024.
The Federal Tax Authority (FTA) is responsible for registration, filing, audits, and enforcement of corporate tax obligations.
The regime is designed to comply with OECD transfer pricing guidelines and the global minimum tax framework (Pillar Two).
The introduction of corporate tax has not diminished the UAE's appeal as a business destination. On the contrary, it has strengthened the country's reputation as a transparent and well-regulated jurisdiction, making it more attractive to multinational corporations and institutional investors.
The corporate tax applies to a broad range of entities and individuals conducting business in the UAE. Understanding whether your business falls within scope is the first step toward compliance.
| Entity Type | Subject to CT | Key Conditions |
|---|---|---|
| UAE mainland companies | Yes | All legal entities incorporated in the UAE |
| Free zone companies | Yes | Subject to CT but may qualify for 0% on qualifying income |
| Foreign entities with UAE PE | Yes | If they have a permanent establishment or nexus in the UAE |
| Individuals in business | Yes | If annual turnover exceeds AED 1 million from business activities |
| Government entities | No | Exempt under the Decree-Law |
| Extractive industries | No | Subject to emirate-level fiscal arrangements instead |
| Investment funds | Conditional | Exempt if they meet qualifying conditions under Cabinet Decision |
Every taxable person must register with the FTA and obtain a Tax Registration Number (TRN), even if they expect to fall below the taxable threshold. Late registration carries a penalty of AED 10,000.
Our tax consultants can assess your specific situation, determine your obligations, and develop a compliant tax strategy tailored to your business structure.
The UAE corporate tax operates on a simple two-tier rate structure designed to protect small businesses while ensuring that larger enterprises contribute fairly.
This threshold effectively shields small businesses and startups from corporate tax during their early growth phase.
One of the lowest corporate tax rates globally, maintaining the UAE's competitive position as a business-friendly jurisdiction.
A higher rate may apply to multinational enterprise groups with global consolidated revenue exceeding EUR 750 million, in line with OECD Pillar Two.
Taxable income is calculated as accounting income adjusted for specific items under the Decree-Law. Businesses can deduct legitimate business expenses, depreciation, and certain provisions. However, items such as fines, penalties, donations (beyond approved limits), and entertainment expenses may be partially or fully non-deductible.
One of the most significant features of the UAE corporate tax regime is the preferential treatment afforded to Qualifying Free Zone Persons (QFZPs). Under Cabinet Decision No. 100 of 2023, free zone entities can benefit from a 0% tax rate on qualifying income.
The entity must have adequate employees, assets, and operating expenditure in the free zone relative to the activities it conducts.
Income must come from qualifying activities such as manufacturing, trading of qualifying commodities, holding of shares, fund management, or services to related free zone entities.
All transactions with related parties must be conducted at arm's length and supported by transfer pricing documentation.
QFZPs must prepare and maintain audited financial statements in accordance with applicable accounting standards.
A Qualifying Free Zone Person cannot simultaneously elect for Small Business Relief.
Non-qualifying income (such as income from mainland customers that is not from a qualifying activity) is taxed at the standard 9% rate. If a QFZP fails to meet any of the qualifying conditions, it loses its preferential status for the entire tax period and the following four tax periods.
The free zone incentive is a powerful tool for businesses that structure their operations correctly. However, the conditions are strict and the consequences of non-compliance are severe. Professional guidance is essential to ensure your free zone entity maintains its qualifying status.
Our team specializes in structuring free zone operations to ensure full compliance with QFZP requirements while optimizing your tax position. Get expert guidance before your next filing deadline.
The Small Business Relief (SBR) provision is designed to reduce the compliance burden on micro and small enterprises during the initial years of the corporate tax regime.
Available to resident taxable persons with revenue of AED 3 million or less in the relevant tax period. Revenue is determined based on the applicable accounting standards.
When elected, taxable income is treated as zero for the tax period, meaning no corporate tax is payable regardless of actual profits.
Available for tax periods ending on or before 31 December 2026. The Ministry of Finance may extend this deadline.
Not available to Qualifying Free Zone Persons or members of a Multinational Enterprise Group with consolidated global revenue exceeding AED 3.15 billion.
While SBR eliminates the tax liability, it comes with important trade-offs. Businesses that elect SBR cannot carry forward tax losses or net interest expenditure from the relief period. This means that if your business incurs losses during a year when SBR is elected, those losses cannot be used to offset future taxable income.
SBR is an excellent short-term tool for small businesses, but the decision to elect it should be made carefully with a view to long-term tax planning. If your business expects to grow beyond the AED 3 million threshold or anticipates significant losses that could be carried forward, it may be more advantageous not to elect SBR.
The UAE's transfer pricing framework is aligned with the OECD Transfer Pricing Guidelines and requires that all transactions between related parties and connected persons be conducted at arm's length.
Transactions between related parties must reflect prices and terms that would be agreed upon between independent parties under comparable circumstances.
Businesses must maintain a master file and local file. Documentation must be provided within 30 days of an FTA request.
A transfer pricing disclosure form must be filed alongside the corporate tax return if related party transactions exceed specified thresholds.
Required for UAE headquarters of MNE groups with consolidated revenue exceeding AED 3.15 billion.
Transfer pricing is one of the most scrutinized areas in international taxation. The FTA has been building its audit capabilities and is expected to increase enforcement activities in 2026 and beyond. Businesses with significant related party transactions should ensure their documentation is robust and up to date.
Compliance with filing obligations is critical. The FTA has established a clear penalty framework that can result in significant financial consequences for non-compliance.
| Item | Detail |
|---|---|
| Tax Registration | Must be completed within the timeframe specified by the FTA. Late registration: AED 10,000 penalty. |
| Tax Return Filing | Within 9 months from the end of the relevant tax period. Late filing: AED 500/month for first 12 months, AED 1,000/month thereafter. |
| Tax Payment | Due on the same date as the tax return filing deadline. Late payment: 14% annual interest rate with no cap. |
| Deregistration | Must be applied for within 3 months of cessation of business. Late deregistration carries penalties. |
| Refund Claims | Must be submitted within 5 years from the end of the relevant tax period (new rule effective 1 January 2026). |
The FTA has expanded its audit powers under the 2025 amendments. It can now issue binding directions requiring taxpayers to take specific actions, and has broader authority to request information and conduct examinations. Maintaining accurate records and timely compliance is more important than ever.
The penalty framework is designed to encourage voluntary compliance. Most penalties can be avoided through timely registration, accurate filing, and prompt payment. However, the cumulative effect of late payment interest at 14% per annum with no cap can be substantial for businesses that fall behind on their obligations.
From registration and compliance to strategic tax planning and free zone structuring, our team of tax experts provides end-to-end support tailored to your business.
Disclaimer: This guide is provided for informational purposes only and does not constitute legal, tax, or financial advice. Tax regulations are subject to change. Always consult with qualified tax professionals before making decisions. Last updated: April 2026.