A UAE free zone company pays 0% corporate tax only if it is a Qualifying Free Zone Person (QFZP). It must have real substance in the free zone, earn qualifying income, keep non-qualifying revenue under the lower of 5% of total revenue or AED 5 million, prepare audited financial statements, follow transfer pricing rules, and not have elected to be taxed at the standard rates. A free zone licence does not give QFZP status by itself. A company that misses a condition at any point in a tax period loses the status for that period and the next four. It is then taxed like a mainland company: 0% on the first AED 375,000 of taxable income and 9% above it. This guide is for 1–10 person companies in DMCC, IFZA, RAKEZ, Meydan and similar free zones that need to know whether the 0% rate really applies. It is general information, not tax advice; confirm your position with the Federal Tax Authority (FTA) or a registered tax agent.

What is a Qualifying Free Zone Person?

A Free Zone Person is any company or branch registered in a UAE free zone. A Qualifying Free Zone Person is one that also meets the conditions in Article 18 of the Corporate Tax Law (Federal Decree-Law No. 47 of 2022) and its implementing decisions. Being a QFZP changes the tax rate:

Company typeRate on qualifying incomeRate on other taxable incomeAED 375,000 zero bandSmall Business Relief
QFZP0%9% from the first dirhamNoNot available
Free zone company that is not a QFZPNot applicable0% up to AED 375,000, 9% aboveYesAvailable if revenue is AED 3 million or less
Mainland companyNot applicable0% up to AED 375,000, 9% aboveYesAvailable if revenue is AED 3 million or less

Every free zone company must register for corporate tax and file a return, whether or not it is a QFZP. Registration and filing are covered in our guide to UAE corporate tax for small companies.

What conditions does a free zone company have to meet?

The conditions come from Article 18 of the law, Cabinet Decision No. 100 of 2023 and Ministerial Decision No. 229 of 2025. The company must meet all of them for the whole tax period.

ConditionWhat it means in practice
Adequate substanceCore income-generating activities carried out in the free zone, with enough qualified full-time staff, assets and operating spending for the activity. Outsourcing is allowed to a provider in a free zone if you supervise it
Qualifying incomeIncome from other Free Zone Persons, or from qualifying activities with anyone else, as explained below
De minimisNon-qualifying revenue no higher than 5% of total revenue or AED 5 million, whichever is lower
Audited financial statementsRequired for every QFZP, whatever its size (Ministerial Decision No. 84 of 2025)
Transfer pricingTransactions with related parties and connected persons at arm's length, with supporting documentation (Articles 34 and 55 of the law)
No electionThe company has not elected to be taxed at the standard rates under Article 19

Threshold: De minimis limit = the lower of 5% of total revenue or AED 5,000,000 in the tax period. For any company with revenue under AED 100 million, the 5% figure is the lower one.

For a small company, substance means the people who do the work are employed by the free zone company and work from its free zone premises. A flexi-desk licence with the owner working from a mainland office is the weak case.

What are the qualifying activities under Ministerial Decision 229 of 2025?

Ministerial Decision No. 229 of 2025, issued on 28 August 2025, replaced Ministerial Decision No. 265 of 2023 with effect from 1 June 2023. It lists 14 qualifying activities:

#Qualifying activity
1Manufacturing of goods or materials
2Processing of goods or materials
3Trading of qualifying commodities (metals, minerals, energy, agricultural commodities and, since MD 229, industrial chemicals, by-products and environmental commodities with a quoted price; not goods packaged for retail sale)
4Holding shares and other securities for investment purposes (held for at least 12 months)
5Ownership, management and operation of ships in international transport
6Reinsurance services
7Fund management services, under UAE regulatory oversight
8Wealth and investment management services, under UAE regulatory oversight
9Headquarter services to related parties
10Treasury and financing services to related parties or for its own account
11Financing and leasing of aircraft
12Distribution of goods or materials in or from a Designated Zone, to customers who resell or process them, or to public benefit entities
13Logistics services (storage, transport, freight forwarding, customs brokerage and similar, without taking title to the goods)
14Activities ancillary to any of the above

The same decision lists excluded activities. Income from these is always non-qualifying:

Consulting, marketing, IT services, design, recruitment, e-commerce and general trading are not on the list. That matters for most small free zone companies.

Which revenue counts as qualifying and which does not?

Cabinet Decision No. 100 of 2023 sorts income by who the customer is and what activity earned it.

CustomerActivityTreatment
Another Free Zone Person that is the beneficial recipientAny activity that is not excludedQualifying
Another Free Zone Person that passes the goods or service on to someone elseAny activityNon-qualifying
Mainland UAE companyQualifying activity (for example logistics or manufacturing)Qualifying
Mainland UAE companyNon-qualifying activity (for example consulting)Non-qualifying
Foreign companyQualifying activityQualifying
Foreign companyNon-qualifying activityNon-qualifying
Any individualMost activities (excluded activity)Non-qualifying
AnyoneIncome of a mainland branch or foreign branchTaxed at 9%, left out of the de minimis test

The beneficial recipient is the customer who uses the service or goods itself and has no obligation to supply them to someone else. A free zone agency that resells your work to a mainland client is not the beneficial recipient.

Two common beliefs are wrong. Foreign clients are not automatically fine: a consultancy billing a London company earns non-qualifying revenue, because consulting is not on the list. Mainland customers are not automatically fatal: a logistics company billing mainland companies keeps that revenue qualifying.

What about mainland customers?

For mainland work, check three things:

  1. Is the activity on the list? If not, every dirham billed to a mainland company counts towards the 5% limit.
  2. Is the customer a company or an individual? Sales to individuals are excluded activities in most sectors, wherever the individual is based.
  3. Do you have a place of business on the mainland? A domestic permanent establishment, such as a mainland office or a staff member habitually concluding contracts there, makes its income taxable at 9%.

Distribution of goods into the mainland qualifies only through a Designated Zone, to customers who resell or process the goods. FTA Decision No. 6 of 2026, according to Deloitte and other advisers, adds an annual agreed-upon procedures report from an independent auditor for QFZPs in Designated Zone distribution, for tax periods starting on or after 1 January 2026. The report is due no later than 30 days after the return deadline.

Worked examples: does 0% apply?

Example 1: a three-person consultancy in IFZA

Calendar-year company, revenue of AED 1,200,000, taxable income of AED 500,000.

LineAED
Consulting for free zone companies (beneficial recipients)600,000
Consulting for mainland LLCs360,000
Consulting for foreign companies240,000
Total revenue1,200,000
Non-qualifying revenue (mainland + foreign)600,000
De minimis limit: lower of 5% × 1,200,000 = 60,000 and 5,000,00060,000
ResultFails: 600,000 is above 60,000

The company is not a QFZP for this period and the next four. It is taxed like a mainland company. Without relief: (500,000 − 375,000) × 9% = AED 11,250. Revenue is under AED 3 million, so if revenue in every earlier period was also AED 3 million or less, it can elect Small Business Relief and pay AED 0. Ministerial Decision No. 131 of 2026 extended the relief to tax periods ending on or before 31 December 2029. For this company the 0% QFZP rate was never available, and Small Business Relief gives the same result without an audit requirement under the corporate tax rules.

Example 2: a five-person logistics company in RAKEZ that passes

Revenue AED 4,000,000. Logistics services to free zone, mainland and foreign companies (no individuals): AED 3,880,000. One consulting project for a mainland client: AED 120,000.

LineAED
Logistics revenue (qualifying activity, company customers)3,880,000
Consulting revenue from a mainland client (non-qualifying)120,000
Total revenue4,000,000
De minimis limit: lower of 5% × 4,000,000 = 200,000 and 5,000,000200,000
ResultPasses: 120,000 is within 200,000
Profit on logistics (qualifying income) at 0%900,000 → tax 0
Profit on consulting (non-qualifying income) at 9%, no zero band50,000 → tax 4,500
Corporate tax as a QFZP4,500

As a non-QFZP the same company would pay (950,000 − 375,000) × 9% = AED 51,750, and revenue above AED 3 million rules out Small Business Relief. QFZP status saves 51,750 − 4,500 = AED 47,250 a year, before the cost of the audit.

Example 3: the same company the following year, with one large mainland contract

Logistics revenue stays at AED 3,880,000, but the mainland consulting work grows to AED 300,000. Total revenue is 4,180,000. The limit is 5% × 4,180,000 = AED 209,000. Non-qualifying revenue of 300,000 is above it, so the company fails.

LineAED
Taxable income: 900,000 logistics + 150,000 consulting1,050,000
Less 0% band(375,000)
Taxed at 9%675,000
Corporate tax for the year60,750

Within the limit, tax would have been 150,000 × 9% = AED 13,500. Status is lost from the start of that year and for the next four, so a 2026 failure means standard rates for 2026 through 2030 even if the consulting stops. Watch the 5% limit during the year, not only at year end.

Can a QFZP use Small Business Relief instead?

No. Ministerial Decision No. 73 of 2023 excludes QFZPs from Small Business Relief. A free zone company has to choose its route:

RouteWho it suitsWhat it costs
QFZP (0% on qualifying income)Companies in listed activities, or serving mainly other free zone companies, with non-qualifying revenue safely under 5%Annual audit, substance, transfer pricing files, tight revenue monitoring
Not a QFZP, with Small Business ReliefCompanies with revenue of AED 3 million or less in this and every earlier period, whatever their activityReturn filed every year; no corporate tax audit requirement
Not a QFZP, standard ratesCompanies above AED 3 million that cannot meet the QFZP conditions9% above AED 375,000 of taxable income

Under Article 19, a QFZP can elect to be taxed at the standard rates, from the start of the period in which it elects or the next one. Not having made this election is one of the QFZP conditions, so advisers generally treat an election as taking the company out of the regime for the same five-period window as a failure. Take advice before electing in or out. Your free zone authority may require audited accounts for licence renewal whichever route you take.

What are the registration and filing deadlines?

QFZPs follow the same calendar as every other company.

Deadline: Register for corporate tax within 3 months of incorporation (FTA Decision No. 3 of 2024, for companies formed on or after 1 March 2024). File the return and pay within 9 months of the end of each tax period. A QFZP attaches audited financial statements for every period starting on or after 1 June 2023.

ItemRule
RegistrationWithin 3 months of incorporation; late registration AED 10,000
Tax return and paymentWithin 9 months of the period end (31 December 2026 year end → 30 September 2027)
Late filing penaltyAED 500 per month for the first 12 months, then AED 1,000 per month
Late payment penalty14% per year on the unpaid tax, charged monthly
AuditEvery QFZP, every period
Designated Zone distributorsAgreed-upon procedures report within 30 days after the return deadline, for periods from 1 January 2026
Record keeping7 years after the end of the tax period

What should your books show to support 0%?

The FTA tests QFZP status against your records. Your books should show:

From the platform: In Staks every invoice is issued to a customer record that carries the customer's tax number, and invoices, expenses, bills and payroll post to a double-entry ledger automatically. The Client Profitability report shows revenue per client for any date range, and each client's invoice list can be exported to CSV, so you can total revenue by free zone, mainland and foreign customers and check it against the 5% limit. The profit and loss, balance sheet and trial balance your auditor needs come from the same ledger. Accounting and reports are on the Growth plan ($49 per month) and above. Staks does not decide which income is qualifying, does not calculate the de minimis test and does not file returns; you or your tax agent make those calls.

Frequently asked questions

Does a free zone licence mean my company pays 0% corporate tax?

No. The licence makes you a Free Zone Person. The 0% rate applies only to qualifying income of a Qualifying Free Zone Person that meets every condition, including the audit and the de minimis limit. Many small free zone service companies are taxed at the standard rates and use Small Business Relief.

Can a free zone consultancy with only foreign clients be a QFZP?

Usually not. Consulting is not a qualifying activity, so revenue from foreign companies is non-qualifying. Only revenue from other Free Zone Persons that are the beneficial recipients would count. If that is less than about 95% of revenue, the company fails the de minimis test.

What happens if I go over the 5% limit by a small amount?

There is no tolerance. Non-qualifying revenue one dirham above the limit ends QFZP status from the start of that tax period and for the next four.

My free zone company sells to individuals online. Does that qualify?

No. Transactions with natural persons are excluded activities except in shipping, fund management, wealth and investment management and aircraft financing. E-commerce sales to consumers are non-qualifying revenue, wherever the buyer lives.

Check your activity against the MD 229 list, total your non-qualifying revenue against the 5% limit, and compare the QFZP route with Small Business Relief before your first return. Start a 14-day free trial of Staks to keep revenue by customer and a ledger your auditor can work from.