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UAE Free Zone Tax Guide

0% tax is not automatic. Miss one condition and you pay 9% for 5 years. Here's how QFZP really works.

The biggest misconception in UAE tax

"I'm in a free zone, so I don't pay tax." — This is wrong. Free zone companies ARE subject to corporate tax. Only those meeting ALL 5 QFZP conditions pay 0%.

Free Zone Tax Basics

Are free zone companies exempt from corporate tax?

No. Free zone companies are subject to corporate tax — but those qualifying as QFZP pay 0% on qualifying income. This is NOT automatic.

Source: Federal Decree-Law No. 47 of 2022, Article 18

What happens if I lose QFZP status?

You pay 9% on ALL income for the current period AND the next 4 tax periods — 5 years total at 9%.

Source: Federal Decree-Law No. 47 of 2022, Article 19

The 5 QFZP Conditions

ALL 5 REQUIRED

Condition 1: Adequate Economic Substance

Real operations in the free zone — employees, office space, expenditure proportional to activities. A shell company with a PO Box will fail.

Source: Ministerial Decision No. 265 of 2023

Condition 2: Qualifying Income

Income from qualifying activities OR transactions with other free zone persons. Revenue from mainland UAE clients is generally NOT qualifying.

Source: Cabinet Decision No. 55 of 2023, Article 3

Condition 3: De Minimis Test

Non-qualifying revenue must not exceed the LOWER of AED 5 million OR 5% of total revenue.

Source: Federal Decree-Law No. 47 of 2022, Article 18

Condition 4: No Mainland Election

Must NOT have elected to be subject to 9%. Once you elect out, cannot re-elect for 5 years.

Source: Federal Decree-Law No. 47 of 2022, Article 19

Condition 5: Transfer Pricing

All related party transactions must be at arm's length (market price). Must maintain transfer pricing documentation.

Source: Federal Decree-Law No. 47 of 2022, Articles 34-36

Mandatory Audit

NEW 2025

Do I need an audit?

Yes. ALL free zone entities claiming QFZP must undergo mandatory audit regardless of revenue, starting tax periods from 1 January 2025.

Source: FTA Guide CTGFZP1, 2025 update

How much does an audit cost?

Small entity: AED 15,000-40,000. Larger: AED 50,000-150,000+. Some advisors suggest calculating whether 9% is cheaper than QFZP compliance.

Source: Industry estimates

Qualifying Activities

What are qualifying activities?

Manufacturing, processing, holding shares/securities, fund management, wealth management, headquarter services, treasury/financing, logistics, distribution in/from designated zones.

Source: Cabinet Decision No. 55 of 2023

Is software development qualifying?

Not explicitly listed. Software sold to mainland clients = likely non-qualifying. IP licensed to free zone persons or exported internationally = may qualify. Grey area — get professional advice.

Source: Cabinet Decision No. 55 of 2023, FTA Clarifications

Last verified: 1 May 2026

Sources: Federal Decree-Law No. 47/2022, Cabinet Decision No. 55/2023, Ministerial Decision No. 265/2023, FTA Guide CTGFZP1. Always check tax.gov.ae.