When does a UAE free zone company pay 0% Corporate Tax?
Short answer
Only a Qualifying Free Zone Person pays 0% on its qualifying income. Under Article 18 of the Corporate Tax Law it must: keep adequate substance in the UAE; earn qualifying income (defined in Cabinet Decision No. 100 of 2023); not have elected to be taxed at the normal rates; comply with the transfer pricing rules (Articles 34 and 55); and meet any other conditions set by the Minister. The qualifying and excluded activities are in Ministerial Decision No. 229 of 2025.
If it fails a condition at any time in a tax period, it stops being a Qualifying Free Zone Person from the start of that period (Article 18(2)). Being in a free zone alone does not give 0%.
What the law says
Federal Decree-Law No. 47 of 2022 on Taxation of Corporations and Businesses, Article 18
Article 18 – Qualifying Free Zone Person
- A Qualifying Free Zone Person is a Free Zone Person that meets all of the following conditions:
a. Maintains adequate substance in the State.
b. Derives Qualifying Income as specified in a decision issued by the Cabinet at the suggestion of the Minister.
c. Has not elected to be subject to Corporate Tax under Article 19 of this Decree-Law.
d. Complies with Articles 34 and 55 of this Decree-Law.
e. Meets any other conditions as may be prescribed by the Minister. - A Qualifying Free Zone Person that fails to meet any of the conditions under Clause 1 of this Article at any particular time during a Tax Period shall cease to be a Qualifying Free Zone Person from the beginning of that Tax Period.
- Notwithstanding Clause 2 of this Article, the Minister may prescribe the conditions or circumstances under which a Person may continue to be a Qualifying Free Zone Person, or cease to be a Qualifying Free Zone Person from a different date.
- The application of paragraph (a) of Clause 2 of Article 3 of this Decree-Law to a Qualifying Free Zone Person shall apply for the remainder of the tax incentive period stipulated in the applicable legislation of the Free Zone in which the Qualifying Free Zone Person is registered, which period may be extended in accordance with any conditions as may be determined in a decision issued by the Cabinet at the suggestion of the Minister, but any one period shall not exceed (50) fifty years.
Decisions and FTA guidance on this
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