An aircraft leasing company in the UAE can reach 0% corporate tax by two routes that most guides merge into one. Ministerial Decision No. 229 of 2025 names "Financing and leasing of Aircrafts" as a Qualifying Activity for a free zone company [1]. Separately, Article 25 of the Corporate Tax Law keeps a foreign lessor's income from leasing aircraft used in international transportation outside Corporate Tax, on a reciprocity condition [2]. The first route is for a UAE company. The second is for a lessor that is not UAE resident at all.
The capital is already moving. In April 2026 Dubai Aerospace Enterprise (DAE) and Blackstone Credit & Insurance launched a platform to invest about USD 1.6 billion a year in aircraft [3], in July 2026 DAE and Neuberger announced a USD 6 billion leasing venture [4], and the UAE aircraft registry passed 1,000 aircraft for the first time [5]. Pick the wrong route and you either carry a substance, audit and de minimis burden you did not need, or claim an exemption your structure cannot use.
Since 2013, BusinessDubai.ae has set up companies across the UAE free zones and the mainland. This guide covers the verbatim Qualifying Activity text, the Article 25 route and its reciprocity test, the DFSA and FSRA question, DIFC, ADGM, Dubai South, DAFZA and mainland structures, costs, the Cape Town Convention, GCAA registration, VAT, transfer pricing and a decision table by business model.
Can an aircraft leasing company in the UAE pay 0% corporate tax?
Yes, by two separate routes. A free zone aircraft lessor that meets every Qualifying Free Zone Person condition can pay 0% on income from item (k) of Ministerial Decision No. 229 of 2025. A foreign lessor with no UAE residence can instead rely on Article 25 of Federal Decree-Law No. 47 of 2022, which turns on reciprocity.
The two routes are not options inside one company. They apply to different taxpayers under different conditions, and a third structure, a Dubai mainland company, has neither. The table sets the three side by side.
| Route | Who can use it | What it gives | Main conditions | Legal basis |
|---|---|---|---|---|
| Qualifying Activity, item (k) | A company resident in a UAE free zone, including DIFC and ADGM | 0% on qualifying income | Adequate substance, qualifying income, no election into ordinary rates, arm's length pricing, audited accounts, de minimis limit | Ministerial Decision No. 229 of 2025, Article 2(1)(k) and 2(3)(k); Federal Decree-Law No. 47 of 2022, Article 18 [1][2] |
| Article 25 exemption | A Non-Resident Person in the business of leasing aircraft used in international transportation | Income not subject to Corporate Tax | Its home jurisdiction would exempt, or not similarly tax, a UAE resident doing the same business | Federal Decree-Law No. 47 of 2022, Articles 22(5) and 25 [2] |
| Dubai mainland licence | A mainland company on the Aircraft & Requisites Leasing activity | Ordinary rates | 0% to AED 375,000 of taxable income, 9% above | Federal Decree-Law No. 47 of 2022 [2] |
Read the "who can use it" column first. Every structuring decision below follows from which taxpayer will earn the lease rentals.
What does the aircraft leasing Qualifying Activity actually cover?
Item (k) of Ministerial Decision No. 229 of 2025 covers financing, leasing and securitisation of aircraft, aircraft engines and rotable components, under finance leases, operating leases or other arrangements, plus related advisory and agency services. It has no Designated Zone condition, and transactions with individuals are excepted from the natural-person exclusion.
Article 2(3)(k) of the decision defines the activity in full [1]:
"Financing and leasing of Aircraft includes the financing, leasing and securitisation of the financing and leasing of Aircraft, Aircraft engines or rotable components, granting the right to use Aircraft, Aircraft engines or rotable components in exchange for rental or other consideration pursuant to a finance lease, operating lease or other arrangement and related advisory and agency services for the procurement, sale or leasing of Aircraft, Aircraft engines or rotable components undertaken by the Qualifying Free Zone Person."
The definition of "Aircraft" in Article 1 is just as wide: "Any machine that can derive support in the atmosphere from the reactions of the air other than the reactions of the air against the surface of the earth" [1]. That takes in helicopters and business jets as well as airliners, and leaves out hovercraft.
Three structural features make item (k) unusually generous. First, it carries no Designated Zone condition, unlike distribution of goods, so a lessor in DIFC or ADGM has the same route as one in an airport zone [1]. Second, Article 2(2)(a) makes "any transactions with natural persons" an Excluded Activity, "except transactions in relation to the Qualifying Activities specified under paragraphs (e), (g), (h) and (k)" [1]. Aircraft are paragraph (k), so a lease to an individual can still produce qualifying income. Third, Article 2(2)(d) excludes "finance and leasing activities" in general, but "without prejudice to the Qualifying Activities specified in paragraphs (c), (e), (j) and (k)" [1]. Aircraft financing and leasing is carved back out of the general exclusion for finance and leasing activities.
The table maps common aviation business models against the text. Where the decision is silent, the table says so.
| Aviation business model | Inside item (k)? | Why |
|---|---|---|
| Operating lease of aircraft to airlines | Yes | "Operating lease" is named [1] |
| Finance lease of aircraft | Yes | "Finance lease" is named |
| Leasing spare engines | Yes | "Aircraft engines" are named |
| Leasing rotable components | Yes | "Rotable components" are named |
| Lending to finance an aircraft, engine or component | Yes | "Financing" is named alongside leasing |
| Securitising aircraft lease or loan receivables | Yes | "Securitisation of the financing and leasing" is named |
| Advisory or agency work on procuring, selling or leasing aircraft | Yes | "Related advisory and agency services" are named |
| Leasing a helicopter or business jet | Yes | Both meet the Article 1 definition of Aircraft [1] |
| Maintenance, repair and overhaul | Not named | Item (k) is financing and leasing; repair is not listed |
| Buying and selling aircraft as stock | Not named | Only advisory and agency work on a sale is named |
| Carrying passengers or cargo as an airline | Not named | Carriage is not listed; a lease with crew is a question for your tax adviser |
The "not named" rows matter because they count as non-qualifying revenue in a company that also leases aircraft, and that revenue is capped.
Pro Tip: Describe your activity in the words of Article 2(3)(k) everywhere it appears: the licence activity, the business plan sent to the zone, the board minutes and the lease agreements. If your lessor leases engines, say "Aircraft engines" rather than "aviation equipment". When the Federal Tax Authority later asks whether income is qualifying, the answer is easiest to prove when your own documents already use the decision's vocabulary [1].
Which Qualifying Free Zone Person conditions still apply to an aircraft lessor?
Every Qualifying Free Zone Person condition applies to an aircraft lessor: adequate substance in the UAE, qualifying income, no election into the ordinary regime, arm's length pricing and transfer pricing compliance, audited financial statements at any revenue, and non-qualifying revenue within the lower of 5% of total revenue or AED 5,000,000.
The conditions come from two instruments. Article 18 of Federal Decree-Law No. 47 of 2022 requires adequate substance in the UAE, Qualifying Income, no election to be taxed at the ordinary rates, and compliance with the arm's length principle and transfer pricing documentation rules [2]. Ministerial Decision No. 229 of 2025 adds audited financial statements and the de minimis test [1]. There is no aircraft-specific relaxation beyond the natural-person waiver and the finance-and-leasing carve-back. Our Qualifying Free Zone Person guide sets out each condition in detail.
A lessor that fails any condition is taxed at the ordinary rates, 0% on the first AED 375,000 of taxable income and 9% above, from the start of that tax period, and cannot be a Qualifying Free Zone Person for the following four periods [2][1]. While the status holds, a Qualifying Free Zone Person gets no AED 375,000 nil band on any non-qualifying income and cannot use Small Business Relief [16].
The de minimis test has a feature that matters for large lessors. Because the cap is the lower of 5% of revenue or AED 5,000,000, it stops growing at AED 100,000,000 of revenue. A lessor with AED 400,000,000 of rentals has the same AED 5,000,000 allowance for non-qualifying income as one with AED 100,000,000.
Quick Math: A lessor earns AED 60,000,000 of lease rentals and AED 3,400,000 from managing engine shop visits for airlines that are not its lessees, an activity item (k) does not name. Total revenue is AED 63,400,000, so the cap is AED 3,170,000, because 5% is lower than AED 5,000,000 [1]. The management fees breach it. On AED 20,000,000 of taxable income the lessor then pays 9% on AED 19,625,000, which is AED 1,766,250 for that period, and loses the status for four more.
Real Talk: Item (k) does not take a large lessor group to 0%. For financial years starting on or after 1 January 2025, the UAE applies a 15% Domestic Minimum Top-up Tax to multinational groups with consolidated revenue of EUR 750 million or more in at least two of the four preceding years [15]. For a group that size, a 0% result in the free zone entity is where the top-up calculation starts. Model the group position before you choose the UAE for the margin.
How does Article 25 exempt a foreign aircraft lessor with no UAE residence?
Article 25 of Federal Decree-Law No. 47 of 2022 takes income of a Non-Resident Person from leasing or chartering aircraft used in international transportation, or leasing equipment integral to their airworthiness, outside Corporate Tax. The condition is reciprocity: a UAE resident doing the same business would be exempt, or not similarly taxed, in the lessor's home jurisdiction.
Article 25 sits in the Exempt Income chapter of the Corporate Tax Law, and Article 22(5) excludes the income it covers from Taxable Income [2]. The article reads in full [2]:
"Income derived by a Non-Resident Person from the operation of aircraft or ships in international transportation shall not be subject to Corporate Tax where all of the following conditions are met:
- The Non-Resident Person is in the Business of any of the following: a. International transport of passengers, livestock, mail, parcels, merchandise or goods by air or by sea. b. Leasing or chartering aircrafts or ships used in international transportation. c. Leasing of equipment which are integral to the seaworthiness of ships or the airworthiness of aircrafts used in international transportation.
- A Resident Person that performs any of the activities under Clause 1 of this Article would be exempt, or not be subject to tax that is of a similar character to Corporate Tax, under the applicable legislation of the country or territory in which the Non-Resident Person is resident."
Three points decide whether it helps you.
It is for a foreign lessor, not a UAE company
Article 25 applies only to a Non-Resident Person. A company incorporated in the UAE, including one in DIFC or ADGM, is a Resident Person under the Corporate Tax Law [2], so it can never use Article 25 and must look to item (k) instead. The route suits a lessor resident in another country that leases aircraft to UAE airlines without becoming UAE resident.
Reciprocity is the whole test
Clause 2 asks how the lessor's home jurisdiction would treat a UAE resident doing the same business. If that jurisdiction would exempt the UAE resident, or not tax it with anything of a similar character to Corporate Tax, the condition is met [2]. We did not find any FTA list of jurisdictions that satisfy the test, or published guidance on how it is assessed. Until there is one, a foreign lessor should get written advice on its home jurisdiction's treatment before relying on Article 25.
No substance, audit or de minimis conditions attach
Article 25 carries none of the Qualifying Free Zone Person conditions. There is no substance test, no audit requirement and no de minimis cap, and no four-period clawback, because it is not a status [2]. Separately, the Corporate Tax Law sets withholding tax at 0% on UAE-sourced income of non-residents under Article 45, so UAE law takes nothing from the rentals at source [2]. Whether staff or an office in the UAE change a foreign lessor's position is a question to put to a tax adviser before the first hire. Our guide to UAE corporate tax on foreign income covers the residence rules in more depth.
Common Mistake: Reading the aircraft exemption as a wet lease versus dry lease test. At least one ranking page frames it that way. Article 25 never mentions wet or dry leases. It asks whether the non-resident is in one of three businesses, international transport, leasing or chartering aircraft used in international transportation, or leasing equipment integral to airworthiness, and whether its home jurisdiction reciprocates [2]. A dry lessor and a wet lessor can both fall inside it, and neither does if reciprocity fails.
Should an aircraft lessor stay offshore under Article 25 or set up as a Qualifying Free Zone Person?
A foreign lessor with no need for UAE staff, and a home jurisdiction that reciprocates, can stay offshore under Article 25 with no UAE substance burden. A lessor that wants UAE management, Cape Town remedies under a UAE vehicle, or a regional platform sets up a free zone company and carries every Qualifying Free Zone Person condition instead.
The comparison below sets out what each route asks of you. Neither is better in the abstract; the right one depends on where your people and your lessees are.
| Factor | Article 25 (offshore lessor) | Item (k) (UAE free zone lessor) |
|---|---|---|
| Who it is for | A Non-Resident Person | A company resident in a UAE free zone |
| How the 0% arises | Income excluded from Taxable Income | 0% rate on qualifying income |
| Core condition | Reciprocity in the home jurisdiction [2] | The full Qualifying Free Zone Person package [2][1] |
| Leasing covered | Leasing or chartering aircraft used in international transportation; leasing equipment integral to airworthiness | Financing, leasing and securitisation of aircraft, engines and rotable components; advisory and agency services |
| Substance in the UAE | Not a condition | Required |
| Audited accounts | Not a condition | Required at any revenue [1] |
| De minimis cap | None | Lower of 5% of revenue or AED 5,000,000 [1] |
| Leases to individuals | Not addressed by the article's text | Expressly permitted by the Article 2(2)(a) waiver [1] |
| Effect of failing | The exemption does not apply, and the ordinary non-resident rules govern the income | Ordinary rates from the start of the period, and four more periods barred |
A third pattern sits between the two: a foreign group keeps an offshore lessor for existing aircraft and opens a UAE free zone platform for new ones. That can work, but the transactions between the two then need arm's length pricing, which the transfer pricing section below covers.
If you are weighing an offshore lessor against a UAE platform, or both in one group, model your position before you commit to a structure→
Do you need a DFSA or FSRA licence to run an aircraft leasing company in the UAE?
Ministerial Decision No. 229 of 2025 attaches no regulatory-oversight condition to aircraft leasing, unlike fund and wealth management, so the 0% route does not itself require a DFSA or FSRA licence. Whether the DIFC or ADGM financial regulator must license your particular activity is a separate question to confirm with the centre before you sign.
The difference is visible in the decision's own wording. Fund management at Article 2(3)(g), wealth and investment management at 2(3)(h), and the general finance and leasing definition at 2(3)(p) each apply only to services "subject to the regulatory oversight of the Competent Authority in the State" [1]. Item (k) carries no such words anywhere in its text. A fund manager has to be regulated before its income can qualify; an aircraft lessor does not.
The decision defines the Competent Authority as the Central Bank, the Dubai Financial Services Authority, the Financial Services Regulatory Authority of ADGM, the Securities and Commodities Authority, or another entity the Minister determines [1]. The federal securities regulator has been the Capital Market Authority, formerly the Securities and Commodities Authority, since 1 January 2026. The decision as published still uses the old name.
The tax text does not answer the licensing question, which belongs to each centre's own rules. Advisory material reports that aircraft leasing SPVs in ADGM register with the ADGM Registration Authority as passive vehicles rather than as FSRA-authorised firms, and law-firm summaries of the DIFC Prescribed Company Regulations 2024 describe an aviation vehicle registered with the DIFC Registrar of Companies [6]. We could not confirm either position from the FSRA or DFSA rulebook text, so treat both as reported. The line is most likely to move for a finance lessor, a lender or a securitisation vehicle, because those activities look more like credit or investments than an operating lease does.
Real Talk: Do not rely on any article, this one included, for the licensing answer. Write one page describing the vehicle: what it owns, who it leases to, how it is financed, whether it lends or securitises, and whether it manages anyone else's money. Send it to the DIFC Registrar or the ADGM Registration Authority and ask whether DFSA or FSRA authorisation is needed. A written reply costs nothing and settles a question the tax text leaves open.
Which UAE structure suits an aircraft lessor: DIFC, ADGM, Dubai South, DAFZA or the mainland?
DIFC and ADGM suit aircraft-owning SPVs and financing structures under common law. Dubai South suits an operating lessor or engine lessor that wants staff beside Al Maktoum International. DAFZA suits aviation parts trading rather than leasing. A Dubai mainland company on DET code 7730020 can lease aircraft but has no 0% route.
Whether you run the lessor from a free zone or the mainland changes the tax route, the audit burden and the vehicles available to you. Our free zone company setup and mainland company setup pages itemise each route, including the year-two renewal that a headline price leaves out.
| Structure | Who registers it | Typical use | Item (k) route | Notes |
|---|---|---|---|---|
| DIFC Prescribed Company, Aviation Structure | DIFC Registrar of Companies [6] | One SPV per aircraft or portfolio | Yes, with every condition met | A structuring vehicle, so substance has to be addressed |
| ADGM SPV | ADGM Registration Authority, as reported | Aircraft-owning and financing SPVs | Yes, with every condition met | Used in early ADGM aviation deals [9] |
| Dubai South company | Dubai Aviation City Corporation | Operating lessor, engine lessor, servicer | Yes, with every condition met | Package pricing on BusinessDubai.ae's sheet [16] |
| DAFZA company | DAFZA | Aircraft parts trading, engine repair | Only if leasing is on the licence | No dedicated leasing code confirmed |
| Dubai mainland, code 7730020 | Department of Economy and Tourism | Leasing aircraft to scheduled operators | No | Ordinary rates; Article 25 also unavailable [10] |
DIFC Prescribed Company with the Aviation Structure purpose
The DIFC Prescribed Company Regulations 2024, effective 15 July 2024, list an Aviation Structure among the qualifying purposes for a Prescribed Company. Law-firm summaries describe it as "a structure involving one or more persons that have a sole purpose of facilitating the owning, financing, securing, leasing or operating of one or more aircraft" [6]. The other qualifying purposes are crowdfunding, intellectual property, maritime and structured financing structures. Our SPV guide itemises the Prescribed Company fees and filings, and our DIFC setup guide covers the centre's other licence routes.
ADGM SPV
ADGM has positioned itself as a tax-efficient aircraft financing and leasing hub, citing a PwC comparative jurisdiction report [7]. In January 2018 it said it was in the process of licensing three aircraft leasing companies, Airborne Capital, Stellwagen Group and International Airfinance Corporation [8]. Etihad Airways and Natixis closed what they described as the first aircraft leasing transactions in ADGM, a sale and leaseback of two A380s through ADGM special purpose companies on 12-year operating leases [9]. Our ADGM company setup guide covers the entity types, and our business setup in Abu Dhabi page compares ADGM with the emirate's other routes, including the Abu Dhabi Airport Free Zone, where you should confirm leasing scope in writing.
Dubai South
Dubai South is regulated by Dubai Aviation City Corporation and holds an Aviation District and the Mohammed bin Rashid Aerospace Hub beside Al Maktoum International. Our Dubai South guide lists financing and leasing of aircraft as a Qualifying Activity for its lessor tenants, and separates it from maintenance, repair and overhaul, which Ministerial Decision No. 229 of 2025 does not name. On BusinessDubai.ae's 2026 package sheet, Dubai South costs AED 12,500 licence only [16].
DAFZA
Dubai Airport Free Zone's register carries 2,044 ISIC-based activities, including Aircraft Spare Parts & Components Trading (4773-708) and Aircraft Engine & Parts Repair & Overhaul (3315-005), as our DAFZA guide sets out. We did not find a dedicated aircraft leasing code on it. DAFZA suits a parts trader beside Dubai International; for a lessor, ask DAFZA in writing which activity it would license.
Dubai mainland on DET code 7730020
The Department of Economy and Tourism lists Aircraft & Requisites Leasing, code 7730020, as a professional activity: "Includes firms specialized in leasing airplanes under lease contracts for air flights in scheduled passenger and freight transport flights including its operational and ground handling tools" [10]. Trading aircraft is a separate commercial activity, Heavy & Light Aircrafts & Helicopters Trading, code 4659306 [10]. A mainland lessor is a Resident Person on ordinary rates, with no Qualifying Free Zone Person route, and Article 25 is closed to it because it is resident [2].
The free zone and mainland comparison for an aircraft lessor comes down to tax treatment and audit, more than ownership.
| Factor | Free zone lessor | Mainland lessor |
|---|---|---|
| Corporate tax on aircraft lease income | 0% on qualifying income as a Qualifying Free Zone Person [1] | 0% to AED 375,000, 9% above [2] |
| Small Business Relief | Not available while claiming the status [16] | Available at or below AED 3,000,000 of revenue, for periods ending on or before 31 December 2029 [16] |
| Activity | Item (k) text and the zone's activity list | DET code 7730020, professional [10] |
| Audited accounts | Required at any revenue [1] | Not triggered by the free zone rules |
| Leases to individuals | Can be qualifying income [1] | No restriction |
| Article 25 | Not available; the company is resident [2] | Not available; the company is resident [2] |
If what you need is a holding company above the lessor rather than the lessor itself, a lighter vehicle may do, and our offshore company formation team can compare that route with a DIFC or ADGM holding structure.
Common Mistake: Treating a DIFC Prescribed Company or ADGM SPV as if registration alone delivers the 0% rate. These vehicles are designed to hold assets, and an SPV typically has no staff of its own, while Article 18 still requires adequate substance in the UAE [2]. Decide before the first delivery where the people who manage the leases sit, whether in a related operating company or a servicer, and get tax advice on how that arrangement supports each SPV's claim.
What does it cost to set up an aircraft leasing company in the UAE?
A desk-based aircraft leasing company at Dubai South costs AED 12,500 licence only, AED 21,050 with one visa and AED 27,600 with two, on BusinessDubai.ae's 2026 package sheet. DIFC, ADGM and DAFZA fees follow their own schedules, and the aircraft, audit and legal costs dwarf every licence line.
The table uses BusinessDubai.ae's 2026 package prices where a zone is on the sheet, each on a stated visa basis [16]. Every other line is set by its authority or quoted on application, and saying so is more useful than an estimate.
| Cost item | Amount (AED) | Notes |
|---|---|---|
| Dubai South package, licence only | 12,500 | 3 activities, 3 shareholders; confirm the leasing activity is on the list [16] |
| Dubai South package, one visa | 21,050 | The first visa adds 8,550 [16] |
| Dubai South package, two visas | 27,600 | The second visa adds 6,550 [16] |
| DIFC Prescribed Company | DIFC Registrar's fee schedule, in US dollars | Incorporation, licence and confirmation statement fees itemised in our SPV guide |
| ADGM SPV | ADGM Registration Authority fee schedule | Add corporate services provider fees; also in our SPV guide |
| DAFZA or Abu Dhabi Airport Free Zone | Quoted on application | Confirm the leasing activity in writing first |
| Dubai mainland, code 7730020 | Quoted per activity and premises | Our mainland page itemises the route |
| GCAA authorising entry point code | 4,000 plus processing | Non-refundable, per CAAP 58 published in 2012; confirm the current fee [11] |
| Audited financial statements | Auditor's quote | Required every period for a Qualifying Free Zone Person [1] |
| Aircraft, insurance, legal and appraisal | Transaction-specific | Outside any licence package |
| Year two | About 80% of year one on a Dubai package | Cards, deposits and compliance items sit outside the headline [16] |
The package rows are office setups for the operating company. For a lessor, the aircraft and its financing sit in a different order of magnitude, and nobody should read the licence lines as the cost of entering this business.
Quick Math: A lessor with AED 10,000,000 of taxable lease income pays AED 866,250 a year at the ordinary rates, which is 9% on AED 9,625,000 [2]. As a Qualifying Free Zone Person on fully qualifying income it pays 0% [1]. A two-visa Dubai South package at AED 27,600, about AED 22,080 in year two at 80% [16], plus an audit, is small against that, and the staff it houses are part of what makes the claim hold.
For an itemised quote across the structures that fit your fleet, with written confirmation of activity scope from each zone, get an itemised aircraft leasing setup quote→
How does the Cape Town Convention protect a lessor leasing aircraft in the UAE?
The UAE is a Contracting State to the Cape Town Convention and its Aircraft Protocol, according to GCAA guidance CAAP 58, and it applies the Article XIII de-registration and export remedy through IDERAs. A 28 August 2024 amendment to the Civil Aviation Law made the Convention prevail over conflicting domestic law.
The General Civil Aviation Authority's CAAP 58 states [11]:
"The United Arab Emirates (UAE) is a Contracting State to the Cape Town Convention and its Aircraft Protocol. The UAE has made a declaration pursuant to Article 30(1) of the Aircraft Protocol that it will apply Article XIII (Article 25 of the Consolidated Text) on de-registration and export request authorization for aircraft registered in United Arab Emirates."
That declaration is the one lessors care about most. It gives a lessor holding an IDERA a recognised route to have an aircraft on the UAE register de-registered and exported on lessee default. We did not find the UAE's accession date in the primary sources reviewed for this guide, so it is not stated here; if a transaction document needs it, take it from UNIDROIT's status records.
The UAE's declarations under the Convention, as listed by UNIDROIT, shape what a lessor can do on default [12].
| UAE declaration | Convention article | What it means for a lessor |
|---|---|---|
| Non-consensual rights with priority | Article 39(1)(a) | Specified non-consensual rights, such as airline worker wage claims, state entity tax liens and repairers' liens, rank ahead of registered international interests in the stated circumstances |
| State services | Article 39(1)(b) | The UAE keeps the right to arrest or detain an aircraft object for amounts owed for services the State provided to it |
| Registrable non-consensual rights | Article 40 | Those non-consensual rights can be registered as international interests |
| Territorial units | Article 52 | The Convention applies to all UAE territorial units |
| Relevant courts | Article 53 | All primary courts within the UAE's territorial jurisdictions are the relevant courts |
| Court leave for remedies | Article 54(2) | Creditor remedies that do not require a court application may be exercised only with leave of the court |
The 2024 amendment closed a gap. Before 28 August 2024, Article 19 of Federal Law No. 20 of 1991, the Civil Aviation Law, described the Convention as complementary to domestic law, which kept the UAE off the OECD's Cape Town discount list, according to a law-firm alert reproduced by Mondaq [13]. The amended Article 19 gives the Convention priority over conflicting domestic provisions. The same alert reports that the UAE became eligible for the OECD Cape Town discount from 22 April 2025, which it describes as up to a 10% reduction in the export credit premium on qualifying aircraft financings [13].
Pro Tip: Get the IDERA lodged with the GCAA at delivery, never at default. CAAP 58 treats it as a creditor's remedy that lets the authorised party procure de-registration and export without further consent from the party that granted it [11]. A lessee in difficulty has no reason to sign one later, so make its recording a condition precedent to delivery in the lease.
Real Talk: Do not assume repossession by notice. Under the UAE's Article 54(2) declaration, creditor remedies that do not otherwise require a court application may be exercised only with leave of the court [12]. Ask your counsel how that declaration interacts with the IDERA route for your aircraft, then draft the default mechanics and your timeline assumptions around a court application, and price the lessee's credit with that in mind.
How are aircraft and lease interests registered with the GCAA?
The General Civil Aviation Authority (GCAA) is the UAE's authorising entry point to the International Registry of Mobile Assets. Under CAAP 58, a lessor or financier obtains a UAE entry point code from the GCAA, for AED 4,000 plus processing, before registering an international interest, and IDERAs are recorded with the GCAA.
CAAP 58 confirms that "the lessor may register its rights and interests in an aircraft in the International Registry" [11], so a lessor, not only an owner or lender, has standing. It also sets which aircraft objects are eligible [11]:
- Airframes type-accepted by the GCAA to carry at least 8 persons including crew, or goods of more than 2,750 kg.
- Helicopters able to carry at least 5 persons including crew, or goods of more than 450 kg.
- Aircraft engines with at least 1,750 lb of thrust for jet engines, or 550 rated take-off shaft horsepower for turbine or piston engines.
CAAP 58 dates from 2012, so confirm the current fee and any revised procedure with the GCAA before you rely on it. The register itself is growing: the UAE aircraft registry passed 1,000 registered aircraft for the first time, Gulf Today reported in July 2026 [5].
CAAP 58 does not set out who may be the registered owner of an aircraft on the UAE register. That is a Civil Aviation Law question for the GCAA, and it is separate from the 100% foreign ownership of the lessor company. An aircraft leased to a foreign airline will usually be registered by that airline's own aviation authority, so the UAE register matters most when the lessee is a UAE operator.
The table sets out who controls what. The free zone authority appears in one row.
| Layer | Authority | What it controls |
|---|---|---|
| Lessor company | The free zone authority, DIFC Registrar, ADGM Registration Authority or DET | The legal entity, its activities, visas and premises |
| Financial-services licence, if any | DFSA, FSRA, Central Bank or Capital Market Authority | Only if the activity is regulated; confirm in writing |
| Aircraft register | GCAA | Registration of aircraft on the UAE register |
| International Registry entry point | GCAA | The UAE entry point code for registering international interests [11] |
| IDERA | GCAA | Recording the de-registration and export authorisation [11] |
| Tax | Federal Tax Authority | Corporate tax, transfer pricing and VAT [2] |
Common Mistake: Assuming the lessor's domicile decides where the aircraft is registered. A DIFC or ADGM lessor can own aircraft on several foreign registers, each run by the lessee's authority, with the Cape Town position of each country to check. Plan the GCAA steps, the entry point code and the IDERA, only for aircraft that will actually sit on the UAE register [11].
Is aircraft leasing subject to VAT in the UAE?
Aircraft designed or adapted for the commercial transport of passengers or goods, and not for recreation or pleasure, are zero-rated under Article 45 of Federal Decree-Law No. 8 of 2017, while private aircraft are standard-rated at 5%. We found no FTA guidance specific to aircraft leases, so confirm how each lease is treated.
Article 45 of the VAT Decree-Law zero-rates the supply of certain qualifying means of transport, and commercial aircraft are the clearest case [14]. The test looks at the aircraft's design and adaptation for commercial transport, so an airliner on lease to a scheduled carrier sits on one side of the line and a private aircraft used for an owner's personal travel sits on the other.
The gap is the lease itself. We did not find FTA guidance that sets out how operating and finance leases of aircraft are treated, as distinct from sales. Read Article 45 with its Executive Regulation, or have your adviser do so, before you invoice a lease as zero-rated [14]. A lessor registers for VAT once taxable supplies pass the AED 375,000 mandatory threshold, or from AED 187,500 voluntarily [16].
Designated Zone status, which DAFZA and the Dubai Aviation City area hold, matters for goods such as spare parts held for re-export rather than for a lessor's rentals. Our Designated Zone VAT guide works through each transaction type.
Real Talk: A private jet structure can pass the corporate tax test and still carry VAT on every rental. Item (k) waives the natural-person exclusion, so rent from an individual can be qualifying income [1], but that waiver is a corporate tax rule and does nothing for VAT. On the Article 45 reading above, a private aircraft is standard-rated, so 5% on an annual rent of AED 2,000,000 is AED 100,000 a year [14].
How should an intra-group aircraft lease be priced for transfer pricing?
An intra-group aircraft lease must be priced at arm's length under Article 34 of Federal Decree-Law No. 47 of 2022, and transfer pricing compliance is itself a Qualifying Free Zone Person condition. A lease rate set for group convenience rather than the market can cost the 0% status, not only trigger an adjustment.
Aircraft leasing groups are built from related-party flows. An SPV leases an aircraft to a group airline, a servicer charges each SPV a management fee, a parent lends to the SPV to fund the purchase, and a group company guarantees the debt. Each flow is a controlled transaction that has to be priced as independent parties would price it [2].
Article 34 names the accepted methods: comparable uncontrolled price, resale price, cost plus, transactional net margin and transactional profit split, with another method allowed where none of these can reasonably be applied [2]. For an operating lease, the comparable uncontrolled price method is the natural starting point, because market lease rates for a given aircraft type and vintage are observable. For a servicer's fee, a cost plus or net margin approach is more common.
The stakes are higher for a free zone lessor than for a mainland one. Article 18 makes compliance with Articles 34 and 55 a Qualifying Free Zone Person condition, so a mispriced lease to a group airline is not only a tax adjustment, it can be a failed condition with the four-period consequence [2]. Our transfer pricing guide sets out the Master File and Local File thresholds and the disclosure form.
Pro Tip: Build the transfer pricing file on the day each lease is signed, not at the year-end. Keep an independent appraiser's market lease rate for the aircraft type and vintage, the servicer's cost base and mark-up, and the interest rate evidence for any intra-group loan. That set answers the arm's length question for each SPV, and the Article 18 condition with it [2].
What has to be filed every year to keep an aircraft lessor compliant?
A UAE aircraft lessor renews its licence or registration yearly, registers for corporate tax on time or pays an AED 10,000 penalty, files a return every period, and, as a Qualifying Free Zone Person, keeps audited accounts at any revenue. VAT returns and International Registry entries run on their own clocks.
The calendar has two halves, the company's filings and each aircraft's registrations, and they run on different cycles.
| Obligation | Authority | When | Source |
|---|---|---|---|
| Licence or registration renewal | The zone, DIFC Registrar, ADGM Registration Authority or DET | Every year | Authority terms |
| Corporate tax registration | Federal Tax Authority | By the FTA deadline; AED 10,000 penalty if late | [16] |
| Corporate tax return | Federal Tax Authority | Every tax period | Federal Decree-Law No. 47 of 2022 [2] |
| Audited financial statements | Required of every Qualifying Free Zone Person | Every tax period, at any revenue | Ministerial Decision No. 229 of 2025 [1] |
| Transfer pricing disclosure and files | Federal Tax Authority | With the return, and on request where thresholds apply | Articles 34 and 55 [2] |
| VAT registration and returns | Federal Tax Authority | Mandatory above AED 375,000 of taxable supplies | [16] |
| International interests | International Registry, through the GCAA entry point | At each delivery, transfer or new financing | CAAP 58 [11] |
| IDERA | GCAA | At delivery of each UAE-registered aircraft | CAAP 58 [11] |
Year two is when these dates start to collide. Licence renewal, visa renewals, the audit and the corporate tax return all fall due within a few months, while each new aircraft brings its own registry filings. Our post-setup services team runs the renewal, visa, corporate tax and VAT calendar so that a filing does not land in the same week as a delivery.
Which UAE structure fits your aircraft leasing business?
Match the structure to the lessor. An operating lessor to international airlines and an engine and rotables lessor fit a free zone item (k) company, a foreign lessor with no UAE presence looks at Article 25, a finance or securitisation vehicle fits DIFC or ADGM, and a private jet owner should test VAT and substance first.
The table is the summary the ranking pages do not publish.
| Your aircraft business | Structure to shortlist | Tax route | What to watch |
|---|---|---|---|
| Operating lessor to international airlines | DIFC Prescribed Company or ADGM SPV per aircraft, with a free zone operating company for staff | Item (k), with no Designated Zone condition [1] | Substance and audited accounts for each entity claiming the status |
| Engine and rotables lessor | Dubai South, or a DIFC or ADGM vehicle | Item (k) names engines and rotable components [1] | Keep repair and trading income inside the de minimis cap |
| Foreign lessor with no UAE presence | No UAE entity | Article 25, subject to reciprocity [2] | Written advice on the home jurisdiction's treatment; withholding tax is 0% [2] |
| Finance lessor or securitisation vehicle | DIFC or ADGM | Item (k) names financing and securitisation [1] | Confirm with the DFSA or FSRA whether the activity is regulated |
| Private jet owner | DIFC Prescribed Company with the Aviation Structure purpose, or an ADGM SPV | Item (k) can apply, including leases to individuals [1] | 5% VAT on private aircraft [14]; substance for a one-aircraft vehicle; arm's length rent |
| Leasing to UAE domestic operators | A free zone item (k) company, or a Dubai mainland company on code 7730020 | Item (k) in a free zone; ordinary rates on the mainland [1][10] | GCAA register and IDERA [11]; Article 25 is closed to any UAE lessor |
The lessor who should slow down is the one whose income mixes leasing with repair, trading or carriage, because that one fact moves the de minimis position, the entity structure and possibly the zone.
Check which structure fits your fleet→
Real Client Stories
These are composite examples built from the situations aircraft lessors most often face when choosing a UAE structure. Names and details are illustrative, and the only figures used are published rules.
Leila's engine leasing company (Dubai South)
Leila, a Lebanese engineer, planned a Dubai South company to lease spare engines to foreign airlines. Item (k) of Ministerial Decision No. 229 of 2025 names aircraft engines and rotable components, so the lease income could qualify. Her plan also included managing engine shop visits for airlines that were not her lessees, an activity item (k) does not name. On projected revenue of AED 40,000,000, her de minimis cap was AED 2,000,000, and the management fees were forecast above it. She placed that work in a separate company before signing the first lease.
Lesson: engines and rotables sit inside item (k); the services around them may not.
Henrik's offshore lessor (no UAE office)
Henrik ran a lessor resident outside the UAE that was about to place two narrowbody aircraft with a UAE airline. A broker suggested a DIFC company to "get the 0%". His adviser pointed out that a DIFC company would be a Resident Person needing substance, audited accounts and the de minimis test, while Article 25 of Federal Decree-Law No. 47 of 2022 could exempt the foreign lessor itself, if its home jurisdiction would exempt a UAE resident doing the same business. With no published reciprocity list, he took written advice on that point first.
Lesson: Article 25 belongs to the foreign lessor, and reciprocity is confirmed, never assumed.
The Al Mansouri family's business jet (DIFC)
A Gulf family planned a DIFC Prescribed Company with the Aviation Structure purpose to own a business jet and lease it to the family's principal for private travel. Item (k) waives the natural-person exclusion, so rent from an individual could be qualifying income. Two other rules decided the plan. A private aircraft is standard-rated for VAT, so each rental invoice would carry 5%, and a Qualifying Free Zone Person needs adequate substance and audited accounts every year, however small. With the rent also set at arm's length, they priced both options before proceeding.
Lesson: for one private jet, VAT and substance decide the structure, not the 0% headline.
Your next steps on a UAE aircraft leasing structure
Three decisions matter for an aircraft lessor, and the licence fee is not one of them. Which taxpayer earns the rentals: a UAE free zone company on item (k), or a foreign lessor relying on Article 25 and its reciprocity test. Whether the entity can carry substance, audited accounts and the de minimis cap year after year. And whether the regulator's position and the Cape Town steps, the entry point code and the IDERA, are confirmed in writing before the first delivery.
BusinessDubai.ae has completed 700+ company registrations across the UAE, with itemised pricing and no hidden fees. We will price a free zone company setup for the lessor or its operating company beside a mainland company setup on code 7730020 where you lease to UAE operators, ask each zone on your shortlist to confirm activity scope in writing, and hand renewals, visas, the audit calendar and corporate tax filings to our post-setup services team.
Talk to an aircraft leasing setup expert→
If your fleet floats rather than flies, our best free zones for marine and shipping guide runs the same 0% analysis for ships.
Frequently Asked Questions
Can a foreign company set up an aircraft leasing company in the UAE?
Yes. UAE free zones, including DIFC, ADGM and Dubai South, allow 100% foreign ownership, and the Dubai mainland register carries an Aircraft & Requisites Leasing activity, code 7730020. The structure decides the tax route: a free zone company can claim item (k) as a Qualifying Free Zone Person, while a mainland company pays the ordinary rates.
Does aircraft leasing qualify for 0% corporate tax in the UAE?
Yes, for a free zone company that meets every Qualifying Free Zone Person condition. Ministerial Decision No. 229 of 2025 lists financing and leasing of aircraft at Article 2(1)(k), covering aircraft, engines and rotable components. Substance, arm's length pricing, audited accounts and the de minimis limit still apply.
Does the 0% rate for aircraft leasing require a Designated Zone?
No. Item (k) of Ministerial Decision No. 229 of 2025 carries no Designated Zone condition, unlike distribution of goods. A lessor in DIFC or ADGM has the same route as one in an airport zone, provided the other Qualifying Free Zone Person conditions are met.
What is the difference between DIFC and ADGM for aircraft leasing?
Both are common-law financial free zones used for aircraft vehicles. DIFC uses a Prescribed Company with the Aviation Structure purpose, registered with the DIFC Registrar, while ADGM aircraft SPVs are reported to register with the ADGM Registration Authority. The 0% test is identical in both, so the choice turns on lessees, financiers, fees and existing group entities.
Do I need a DFSA or FSRA licence to lease aircraft in the UAE?
Not for the 0% tax test, because Ministerial Decision No. 229 of 2025 attaches no regulatory-oversight condition to aircraft leasing. Whether the DFSA or FSRA must license your activity is a separate question. ADGM aircraft SPVs are reported to register with the Registration Authority rather than the FSRA, but confirm your structure in writing, especially for finance leasing or securitisation.
Does Article 25 of the UAE Corporate Tax Law apply to a DIFC or ADGM company?
No. Article 25 of Federal Decree-Law No. 47 of 2022 applies only to a Non-Resident Person, and a company incorporated in the UAE, including in DIFC or ADGM, is a Resident Person. A UAE lessor's route to 0% is item (k) as a Qualifying Free Zone Person instead.
Can a non-resident lessor avoid UAE corporate tax on aircraft leasing income?
Yes, if Article 25 of Federal Decree-Law No. 47 of 2022 applies. Income of a Non-Resident Person from leasing or chartering aircraft used in international transportation, or leasing equipment integral to their airworthiness, is not subject to Corporate Tax where the lessor's home jurisdiction would exempt, or not similarly tax, a UAE resident doing the same business.
What is the reciprocity condition in Article 25 of the UAE Corporate Tax Law?
The reciprocity condition requires that a UAE Resident Person doing the same business would be exempt, or not subject to tax similar to Corporate Tax, in the country where the non-resident lessor is resident. We found no published FTA list of jurisdictions that meet it, so a foreign lessor should take written advice on its home jurisdiction before relying on it.
Is the UAE aircraft tax exemption about wet leases versus dry leases?
No. Article 25 of the Corporate Tax Law does not mention wet or dry leases. It asks whether the non-resident is in international transport, leasing or chartering aircraft used in international transportation, or leasing equipment integral to airworthiness, and whether its home jurisdiction reciprocates.
Does the UAE charge withholding tax on aircraft lease payments to a foreign lessor?
No. The Corporate Tax Law sets withholding tax at 0% on UAE-sourced income of non-residents under Article 45 of Federal Decree-Law No. 47 of 2022. The lessor's tax position in its own country is a separate question.
Does leasing aircraft engines or rotable parts qualify for the 0% free zone rate?
Yes. Article 2(3)(k) of Ministerial Decision No. 229 of 2025 names "Aircraft engines or rotable components" alongside aircraft, under finance leases, operating leases or other arrangements. Outright trading of spare parts and repair work are not named, so that income counts as non-qualifying.
Can an aircraft lessor lease to an individual and still get 0% tax in the UAE?
Yes. Article 2(2)(a) of Ministerial Decision No. 229 of 2025 makes transactions with natural persons an Excluded Activity but waives that for paragraph (k), aircraft. A lease to an individual can therefore produce qualifying income if the other conditions are met. VAT is a separate question, and private aircraft are standard-rated.
What happens if an aircraft leasing company fails a Qualifying Free Zone Person condition?
It is taxed at the ordinary rates, 0% on the first AED 375,000 of taxable income and 9% above, from the start of the tax period in which it failed. It also cannot be a Qualifying Free Zone Person for the following four tax periods. Breaching the de minimis cap with repair or trading income is one common trigger.
How large can non-qualifying income be for an aircraft lessor?
Non-qualifying revenue must not exceed the lower of 5% of total revenue or AED 5,000,000 in a tax period, under Ministerial Decision No. 229 of 2025. Above AED 100,000,000 of revenue the cap stays at AED 5,000,000, however large the lessor becomes.
Do aircraft lessors in UAE free zones need audited accounts?
Yes. A Qualifying Free Zone Person must prepare audited financial statements every tax period, at any revenue, under Ministerial Decision No. 229 of 2025. This applies to each SPV that claims the status, not only to the group's operating company.
Can an aircraft leasing company claim Small Business Relief instead of Qualifying Free Zone Person status?
Only if it gives up the status. Small Business Relief is available where revenue is at or below AED 3,000,000 for tax periods ending on or before 31 December 2029, under Ministerial Decision No. 131 of 2026, but a Qualifying Free Zone Person cannot use it. Few aircraft lessors fall under that revenue line.
Does Dubai South qualify for the aircraft leasing 0% rate?
Yes, if the company meets every Qualifying Free Zone Person condition, because item (k) has no Designated Zone condition. Dubai South's Aviation District sits beside Al Maktoum International, and BusinessDubai.ae's 2026 package sheet prices Dubai South at AED 12,500 licence only and AED 21,050 with one visa.
Can DAFZA be used for an aircraft leasing company?
Possibly, but confirm it in writing first. DAFZA's register carries aircraft spare parts trading and engine repair activities, and we did not find a dedicated aircraft leasing code on it. DAFZA suits a parts trader beside Dubai International more naturally than a lessor.
Is aircraft leasing a professional or commercial activity on the Dubai mainland?
Aircraft leasing is a professional activity on the Dubai mainland, listed by the Department of Economy and Tourism as Aircraft & Requisites Leasing, code 7730020. Trading aircraft is a separate commercial activity, Heavy & Light Aircrafts & Helicopters Trading, code 4659306.
Does a Dubai mainland aircraft leasing company pay 0% corporate tax?
No. A mainland company has no Qualifying Free Zone Person route, so it pays 0% on the first AED 375,000 of taxable income and 9% above. Article 25 is also closed to it, because a company incorporated in the UAE is a Resident Person.
Can a DIFC Prescribed Company be used for aircraft leasing?
Yes. The DIFC Prescribed Company Regulations 2024 list an Aviation Structure among the qualifying purposes, described in law-firm summaries as a structure with the sole purpose of facilitating the owning, financing, securing, leasing or operating of aircraft. To claim 0%, the company still has to meet the substance condition.
Can an ADGM SPV hold a leased aircraft?
Yes. Etihad Airways and Natixis used ADGM special purpose companies for a sale and leaseback of two A380s on 12-year operating leases, described as the first aircraft leasing transactions in ADGM. Confirm with the ADGM Registration Authority whether your specific vehicle needs FSRA authorisation.
Is the UAE a Cape Town Convention country?
Yes. GCAA guidance CAAP 58 states that the UAE is a Contracting State to the Cape Town Convention and its Aircraft Protocol, and that it applies Article XIII on de-registration and export request authorisation. This guide does not state an accession date because the primary sources reviewed did not give one.
What is an IDERA in the UAE?
An IDERA is an Irrevocable De-Registration and Export Request Authorisation. Under GCAA guidance CAAP 58 it is recorded with the GCAA and works as a creditor's remedy, letting the authorised party procure de-registration and export of the aircraft on lessee default. Lessors usually require it at delivery.
Does the UAE qualify for the OECD Cape Town discount on aircraft financing?
Yes, from 22 April 2025, according to a law-firm alert published by Mondaq. A 28 August 2024 amendment to Article 19 of the Civil Aviation Law gave the Convention priority over conflicting domestic law, and the alert describes the discount as up to a 10% reduction in the export credit premium.
How do I register an aircraft lease on the International Registry from the UAE?
Obtain a UAE authorising entry point code from the GCAA, then register the international interest on the International Registry. GCAA guidance CAAP 58 confirms a lessor may register its rights and interests, and states a non-refundable fee of AED 4,000 plus processing, in a 2012 document, so confirm the current fee.
Which aircraft can be registered on the International Registry through the UAE?
GCAA guidance CAAP 58 covers airframes able to carry at least 8 persons or more than 2,750 kg of goods, helicopters able to carry at least 5 persons or more than 450 kg, and engines of at least 1,750 lb thrust or 550 shaft horsepower. Smaller aircraft objects fall outside the Convention's registry.
Can a foreign-owned aircraft be registered in the UAE?
GCAA guidance CAAP 58 does not state the ownership test for the UAE aircraft register, so confirm eligibility with the GCAA under the Civil Aviation Law. That test is separate from the 100% foreign ownership of the lessor company, and an aircraft leased to a foreign airline is usually registered by that airline's own authority.
Is aircraft leasing income subject to VAT in the UAE?
It depends on the aircraft. Aircraft designed or adapted for commercial transport, and not for recreation, are zero-rated under Article 45 of Federal Decree-Law No. 8 of 2017, while private aircraft are standard-rated at 5%. We found no FTA guidance specific to leases, so confirm each lease's treatment before invoicing.
Does the 15% top-up tax affect large aircraft leasing groups in the UAE?
Yes, for multinational groups with consolidated revenue of EUR 750 million or more. For financial years starting on or after 1 January 2025, Cabinet Decision No. 142 of 2024 applies a 15% Domestic Minimum Top-up Tax to those groups, so a 0% Qualifying Free Zone Person result can be topped up [15]. Smaller lessors are outside it.
References
[1] Ministry of Finance. Ministerial Decision No. 229 of 2025 Regarding Qualifying Activities and Excluded Activities: Article 1 definitions of Aircraft and Competent Authority, Article 2(1)(k), Article 2(2)(a) natural-person exclusion and its waiver for paragraphs (e), (g), (h) and (k), Article 2(2)(d) and its carve-back for paragraphs (c), (e), (j) and (k), Article 2(3)(g), (h), (k) and (p), Article 3 de minimis, and Article 5 audited financial statements and loss of status. mof.gov.ae
[2] Federal Tax Authority. Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses: ordinary rates, Resident Person rules, Article 18 Qualifying Free Zone Person conditions and loss of status, Article 22(5) and Article 25 on Non-Resident Persons operating or leasing aircraft in international transportation, Article 34 arm's length principle and methods, and Article 45 withholding tax at 0%. tax.gov.ae
[3] The National. Dubai plane lessor DAE partners with Blackstone to invest USD 1.6 billion annually in a portfolio, 9 April 2026. thenationalnews.com
[4] The National. Dubai plane lessor DAE and US-based Neuberger launch USD 6 billion leasing venture, 6 July 2026. thenationalnews.com
[5] Gulf Today. UAE aircraft registry surpasses 1,000 aircraft for the first time, 22 July 2026. gulftoday.ae
[6] Dubai International Financial Centre. Prescribed Company Regulations 2024, effective 15 July 2024: the Aviation Structure qualifying purpose and its definition and registration with the DIFC Registrar of Companies, as reported in law-firm summaries by Morgan Lewis and DLA Piper. difc.com
[7] Abu Dhabi Global Market. ADGM recognised as an attractive and tax efficient aircraft financing and leasing hub for the region, citing PwC's comparative jurisdiction report. adgm.com
[8] The National. ADGM says it is licensing three aircraft leasing companies, naming Airborne Capital, Stellwagen Group and International Airfinance Corporation, 23 January 2018. thenationalnews.com
[9] Groupe BPCE newsroom, reproducing the ADGM release. Etihad Airways and Natixis close the first aircraft leasing transactions in Abu Dhabi Global Market: sale and leaseback of two A380s through ADGM special purpose companies on 12-year operating leases. newsroom-en.groupebpce.fr
[10] Dubai Department of Economy and Tourism. Business activity list as recorded in a public copy of the register: code 7730020 Aircraft & Requisites Leasing (professional) with its official description, and code 4659306 Heavy & Light Aircrafts & Helicopters Trading (commercial), records dated 24 October 2023. invest.dubai.ae
[11] General Civil Aviation Authority. Civil Aviation Advisory Publication CAAP 58, Guidance on Aircraft Registry Requirements, released 30 August 2012: Contracting State status, the Aircraft Protocol declaration applying Article XIII, the GCAA as authorising entry point and its AED 4,000 fee, aircraft object thresholds, lessor registration and IDERA recording. gcaa.gov.ae
[12] UNIDROIT. Declarations lodged by the United Arab Emirates under the Cape Town Convention: Articles 39(1)(a), 39(1)(b), 40, 52, 53 and 54(2). unidroit.org
[13] Mondaq, reproducing a law-firm client alert. The UAE amends the Federal Civil Aviation Law to secure Cape Town Convention financing benefits: the 28 August 2024 amendment to Article 19 of Federal Law No. 20 of 1991 and eligibility for the OECD Cape Town discount from 22 April 2025. mondaq.com
[14] UAE Legislation. Federal Decree-Law No. 8 of 2017 on Value Added Tax: Article 45 zero-rating of qualifying means of transport, including aircraft designed or adapted for commercial transport. uaelegislation.gov.ae
[15] Ministry of Finance. Cabinet Decision No. 142 of 2024 on the Imposition of Top-up Tax on Multinational Enterprises, issued under Federal Decree-Law No. 60 of 2023: scope of EUR 750 million in at least two of the four preceding fiscal years, effective for fiscal years starting on or after 1 January 2025. tax.gov.ae
[16] BusinessDubai.ae. Internal pricing reference: owner-confirmed 2026 free zone package prices by visa count for Dubai South, the year-two renewal guide, and the accompanying corporate tax summary (ordinary rates, Qualifying Free Zone Person nil-band and Small Business Relief rules, Ministerial Decision No. 131 of 2026), VAT registration thresholds and the AED 10,000 late registration penalty, as at 24 September 2026. businessdubai.ae
