Qualifying Free Zone Person (QFZP): Do You Qualify for 0%, How Do You Stay Qualified, and What Does One Breach Cost You?

Here is the number that should change how you treat this. If a Qualifying Free Zone Person fails any one of its conditions at any point in a tax period, Article 5(2) of Ministerial Decision No. 229 of 2025 says it "shall cease to be a Qualifying Free Zone Person from the beginning of the relevant Tax Period and for the subsequent (4) four Tax Periods" [1]. That is five tax periods at 9%, not one. Guides that say you "lose your 0% for that year" are wrong by four years.

The second thing to fix is the mental model. The 0% is not a feature of your licence. It is a conditional exemption under Articles 3(2), 18 and 19 of Federal Decree-Law No. 47 of 2022 that you re-earn every tax period by doing listed activities, keeping substance in the zone, staying under a cap on the wrong revenue, getting audited and holding transfer pricing documentation [3]. The licence gets you into the room. Article 18 decides whether you keep the rate.

This guide is the operational one: whether you qualify, how you stay qualified, and what one slip costs. For the difference between a free zone, a special economic zone and a Designated Zone, see our special economic zones vs free zones guide. Since 2013 our team has structured free-zone companies across the UAE, so the traps come from real files. This is a guide, not legal or tax advice.

What is a Qualifying Free Zone Person, exactly?

A QFZP is a Free Zone Person meeting every condition in Article 18(1) in a given tax period, which gives 0% on Qualifying Income and 9% on everything else. There is no certificate or application: you self-assess in your return, the Federal Tax Authority can test it later, and within a period the status is binary [3].

One instrument note. Cabinet Decision No. 55 of 2023 on Qualifying Income was repealed by Article 10 of Cabinet Decision No. 100 of 2023, both retroactive to 1 June 2023 [2][8], so any page citing CD 55/2023 as current is quoting a repealed text. The live instruments are CD 100/2023 and MD 229/2025, and our free zone company setup page covers what each zone option will and will not support.

What are the five conditions?

Article 18(1) sets five, and each one is independently fatal [3].

Condition 5 is where founders get caught, because it keeps growing. Article 5(1) of MD 229/2025 uses it for de minimis and for audited financial statements, which turns an accounting task into a status condition [1].

Common Mistake: Treating the five conditions as a year-end checklist. Article 18(2) says failure "at any particular time during a Tax Period" is enough, so a quarter in which your only qualified employee had resigned unreplaced is a quarter in which substance may have failed. December remediation does not retro-fit it.

Which activities actually qualify for 0%?

Article 2(1) of MD 229/2025 lists fourteen Qualifying Activities. The list is closed, with no general services category and no catch-all. If your activity is not on it, and is not genuinely ancillary to something on it, it is not a Qualifying Activity [1].

Fund management and wealth and investment management, (g) and (h), are limited to services subject to the regulatory oversight of the Competent Authority in the State: the Central Bank, the DFSA, the FSRA in ADGM, the Securities and Commodities Authority, or a Minister-designated body [1]. An unregulated advisory firm does not qualify simply because its subject matter is money.

Ancillary activities, (n), are defined at Article 2(4) as necessary for a listed main activity, or making only a minor contribution to it and so closely related they should not be regarded as separate [1]. Ancillary attaches to a main activity you already perform, and does not convert a standalone service line into a qualifying one.

Real Talk: If you run a consultancy, an agency, an IT services firm, a recruitment business or a general trading company in retail-packaged goods, read that table again slowly. None of those appear. For a service business the honest answer is usually a mainland licence and the standard rate ladder, so our mainland company setup page is the more useful read, and our free zone vs mainland for a software company guide works a profile like this through.

Which activities are excluded outright?

Article 2(2) sets the Excluded Activities. Revenue from these is non-qualifying whoever the counterparty is, and counts against your de minimis cap [1]. The carve-backs matter as much as the exclusions.

Exclusion (a) reshapes business models. A business-to-consumer model in a free zone is structurally incompatible with a meaningful QFZP claim, because every consumer sale is excluded revenue rather than merely non-qualifying revenue.

Exclusion (e) surprises property investors. The only carve-back is Commercial Property in a Free Zone let to a Free Zone Person, so residential property and commercial property let to anyone else sit outside it, and CD 100/2023 carves property income out of Qualifying Income separately as well [2].

Does the 51% test apply to logistics and distribution?

No, and this is the most widely garbled point in the commentary. The 51% test sits inside the definition of commodities trading at Article 2(3)(c) and does not attach to (m) logistics services or (l) Designated Zone distribution [1].

Article 2(3)(c) defines the trading of Qualifying Commodities to cover physical trading plus associated hedging derivatives and associated structured commodity financing, provided the activity is not conducted by a QFZP whose revenue from distribution, warehousing, logistics or inventory management functions constitutes 51% or more of its revenue for the Tax Period [1]. It is a boundary around one heading, stopping a warehouse business from calling itself a commodity trader, not a general revenue-mix rule.

Two definitional points inside the heading. Structured commodity financing is defined broadly, expressly including prepayment, factoring, forfaiting, countertrade, warehouse receipt financing, export receivable financing, project finance, Islamic trade finance and streaming financing. And Qualifying Commodities exclude products packaged for retail sale [1], so a bulk trader in metals, minerals, energy or agricultural commodities can be in scope while an importer of consumer-packaged goods cannot use this heading. Pricing interacts with Ministerial Decision No. 230 of 2025 on Recognised Price Reporting Agencies [7].

Pro Tip: For a logistics business the Article 2(3)(m) definition is the friend and title is the enemy. It covers cargo handling, warehousing, container storage, transport agency, customs brokerage, order and inventory management, freight forwarding and brokerage, document preparation, packing and unpacking, all without taking title to the goods [1]. The moment a contract has you buying and reselling rather than handling for a principal, you are outside (m). Talk to a setup expert→

How does the de minimis rule actually work?

Under Article 3 of MD 229/2025, with mechanics in Article 4 of CD 100/2023, it is satisfied where non-qualifying revenue does not exceed 5% of total revenue, or AED 5,000,000, whichever is lower [1][2]. The cap stops scaling at AED 100 million of revenue, above which the absolute figure bites and the percentage is irrelevant.

Non-qualifying revenue is the total of three things under Article 4 of CD 100/2023: revenue from Excluded Activities, whoever the counterparty is; revenue from activities that are not Qualifying Activities where the counterparty is a non-Free Zone Person; and revenue from any transaction with a Free Zone Person who is not the Beneficial Recipient [2]. That third limb is the quiet one: a sale to a free zone conduit is non-qualifying even though the invoice says Free Zone Person.

Article 4(3) then removes three categories from both sides of the fraction: free zone immovable property revenue, revenue attributable to a domestic or foreign Permanent Establishment, and IP revenue other than Qualifying IP income [2]. Removing them from the denominator matters too, because heavy property or PE revenue does not buy a bigger allowance.

Quick Math: A free zone distributor with AED 40,000,000 of total revenue has a cap of AED 2,000,000. It takes a mainland services contract worth AED 2,600,000. De minimis fails, Article 18 fails with it, and the company is not a QFZP for that period or the next four. One contract cost five years of the rate.

What happens when you breach a condition?

You lose the status from the beginning of the period in which the breach happened, and for the following four tax periods. Article 18(2) of FDL 47/2022 provides that failing any condition at any time during a tax period means ceasing to be a QFZP from the beginning of that period, and Article 18(3) lets the Minister prescribe a different duration, which Article 5(2) of MD 229/2025 uses against you [1][3].

Quick Math: A free zone trader with AED 8,000,000 of taxable income pays nothing as a QFZP. It breaches one condition, say by letting the audit lapse. Five periods at 9% is roughly AED 3,600,000 against AED 0, and year one has already closed. The clawback is not a penalty bolted on to the regime. It is the enforcement mechanism.

Based on our experience, the breaches we see are boring: a contract signed by sales without anyone testing it against the activity list, a qualified employee replaced by a contractor in another emirate, an audit "being arranged" when the deadline arrived. The control that works is simple. No revenue line goes live until someone has mapped it to a heading in Article 2(1), or accepted it against the cap in writing.

Why is there no AED 375,000 buffer for a QFZP?

Because Article 3(2) does not contain one, and this is conflated on nearly every consultancy page we checked. Article 3(1) gives an ordinary taxable person 0% up to AED 375,000, set by Cabinet Decision No. 116 of 2022, then 9%. Article 3(2) gives a QFZP 0% on Qualifying Income and 9% on everything else, with no threshold anywhere in it [3].

So a QFZP with AED 300,000 of non-qualifying taxable income pays roughly AED 27,000, while a free zone company that is not a QFZP with the same AED 300,000 pays nothing, because it has the Article 3(1) band. Being outside the regime is not a punitive category. Our corporate tax filing requirements guide covers the return mechanics either way.

What does the substance test require?

Real activity in the zone, evidenced. Under Article 8 of CD 100/2023, adequate substance means undertaking your Core Income Generating Activities in a Free Zone or Designated Zone as the activity requires, with adequate assets, adequate qualified full-time employees and adequate operating expenditure, having regard to your level of activities [2].

CIGAs are the significant functions that drive business value: production for a manufacturer, the trading, risk and pricing decisions for a commodity trader, handling and movement for a logistics provider. Bookkeeping and administration are not CIGAs, and performing only those in the zone is the classic thin-substance profile. "Adequate" is deliberately relative, with no published headcount, floor area or expenditure minimum, so a company invoicing AED 80 million from a flexi-desk has a problem that one invoicing AED 800,000 does not.

That answers the group service company question. Ordinary CIGAs may be outsourced, including to a Related Party, but the provider must sit in a Free Zone or Designated Zone, so a mainland affiliate or offshore group entity does not qualify [2]. Supervision must be real and documented: instructions given, output reviewed, decisions taken by your people.

Common Mistake: Buying the thinnest possible package and then claiming 0%. The zone does not have to defend your substance to the FTA, and adequacy is judged against your own level of activity, so the more successful you become, the weaker a thin structure looks.

Why does every QFZP need audited accounts, whatever its size?

Because the audit rule has two limbs and the QFZP limb has no threshold. Article 2(1) of Ministerial Decision No. 84 of 2025 requires audited financial statements from (a) a taxable person that is not a Tax Group whose revenue exceeds AED 50,000,000, and (b) a Qualifying Free Zone Person [4]. Limb (b) stands alone, with no "and whose revenue exceeds" attached. It applies to tax periods commencing on or after 1 January 2025, and repealed MD 82/2023.

Now the part that makes this a status issue. Article 5(1)(b) of MD 229/2025 makes audited financial statements an explicit condition of QFZP status [1]. Put that beside Article 5(2) and a missed audit is a failed Article 18 condition that can trigger the five-period disqualification on its own. An unaudited QFZP is a nine-percent taxpayer that has not noticed yet.

One honest flag on the drafting. Article 2(3) of MD 84/2025 still cross-references Ministerial Decision No. 265 of 2023 for the Designated Zone distribution procedures, and MD 265/2023 was repealed by Article 6 of MD 229/2025 [1][4]. We could not confirm any correcting amendment, so treat it as a live drafting inconsistency and read it as pointing to the equivalent provision in MD 229/2025.

The audit is therefore a fixed annual cost that arrives with the status. Our do all UAE companies need an audit guide covers the wider picture, and the annual cycle of audit, filing and renewals is the work our post-setup services team runs so a condition never fails because a deadline slipped.

When are you better off not being a QFZP?

More often than the marketing suggests. For a small company, being an ordinary taxable person can mean less tax and much less risk, because the ordinary regime offers two reliefs a QFZP is denied: the AED 375,000 band, and Small Business Relief, which Article 3(2) of Ministerial Decision No. 73 of 2023, as amended by Ministerial Decision 131 of 2026 bars a Qualifying Free Zone Person from electing [5].

Work it through for a free zone company with AED 2,500,000 of revenue and AED 600,000 of taxable income whose activity is not on the Article 2(1) list, the position of most service businesses.

The QFZP route is the most expensive of the three and the only one with a five-period tail. A 0% rate you do not qualify for is a liability with a marketing budget behind it.

Real Talk: Note the sunset. Small Business Relief runs only for periods ending on or before 31 December 2029, so for most companies 2029 is now the last eligible year [5]. After that the comparison narrows to the AED 375,000 band against a genuine QFZP claim, which raises the bar on the activity analysis. If your activity is on the list, build the substance and take the 0%. If not, the answer is usually a mainland licence with proper market access, and our mainland company setup page sets out what that involves. Our free zone vs mainland vs offshore comparison covers the trade-offs, and to test it on your own numbers, talk to a setup expert→

Can you elect out of the QFZP regime?

Yes, and you should assume you cannot elect back in. Article 19 of FDL 47/2022 lets a QFZP elect to be taxed under Article 3, effective from the start of the period the election is made in or the following one. The law contains no mechanism to revoke an election, and Article 18(1)(c) makes not having elected a condition of QFZP status in the first place [3]. Read together, that is a permanent exit, so treat it as irrevocable.

It makes sense mostly where the claim was always marginal and the compliance cost is real: a drifting activity mix, a wish to use the AED 375,000 band and Small Business Relief while you are under the threshold, customers increasingly mainland or natural persons, or an unwillingness to carry a mandatory audit for a rate you barely use.

How do the permanent establishment and property carve-outs work?

They are applied before the activity analysis, which is why they catch people who checked the activity list carefully. Under Articles 3, 5 and 6 of CD 100/2023, Qualifying Income excludes income attributable to a domestic or foreign Permanent Establishment, and income from the ownership or exploitation of immovable property other than the Commercial Property carve-back [2]. That income is taxed at 9% under Article 3(2)(b), and Article 4(3) removes it from both sides of the de minimis test [2][3].

The domestic PE test is the counterintuitive one. It applies Article 14 of the CT Law with two substitutions: read "Qualifying Free Zone Person" for "Non-Resident Person", and "geographical areas outside the Free Zones in the State" for "State" [2]. You test your own mainland presence as you would a foreign company's UAE presence.

Pro Tip: This quietly undoes good structures. A free zone company that opens a mainland sales office, keeps staff working from a mainland location, or lets an agent habitually conclude contracts there can create a domestic PE taxed at 9%. It usually signals a licensing question too. Decide market access at the start, not in a tax review.

What about VAT? Keep it in its own lane

QFZP status is a corporate tax concept. Designated Zone status is a VAT concept, under which certain fenced free zones are treated as outside the State for VAT on goods, while services inside them are generally standard-rated. They overlap in one place: activity (l), Designated Zone distribution, borrows the VAT concept as a geographic condition for a corporate tax heading [1]. Being in a Designated Zone does not make you a QFZP, and QFZP status does not change your VAT position. Our Designated Zones and VAT guide covers that regime.

Why do rules published in 2025 apply to 2023?

Because they say so, and this is the most under-reported feature of the regime. MD 229/2025 was issued on 28 August 2025 and repealed MD 265/2023 at Article 6, but Article 7 states that it comes into effect on 1 June 2023 [1]. It governs the qualifying analysis for periods that had already ended and been filed. Most commentary presents MD 229 as forward-looking. It is not.

The guidance layer has the same problem. The FTA's Corporate Tax Guide on Free Zone Persons, CTGFZP1, was published around 26 May 2024, so it predates both MD 229/2025 and MD 84/2025 and does not reflect the current activity list, the widened treasury wording or the unconditional audit rule [6]. If a consultant quotes it to you on the activity list, they are quoting a document written before the list changed.

So what about closed periods? Re-run the activity analysis for every period from 1 June 2023 against MD 229/2025, noting whether the widened treasury wording or the logistics definition changes a position you previously conceded. Where it moves against you, get advice on the voluntary disclosure route before the FTA raises it. We could not establish any published FTA concession for good-faith positions taken under the repealed MD 265/2023, so do not assume one exists. The ongoing filing side is work our post-setup services team coordinates alongside the audit.

Your year-end QFZP checklist

Run this before the year closes. Every line maps to an Article 18 condition, so every line carries the five-period consequence.

Choosing the right zone and licence at the outset removes several of these checks, and our free zone company setup page covers how we match activity, zone and premises to a defensible claim.

Real Client Stories

Real examples from businesses we have helped, with details changed for privacy.

The logistics company told it had failed a test that did not apply. A freight forwarding and warehousing business was advised its QFZP status was gone because warehousing revenue exceeded half its turnover. It had not: the 51% condition sits inside the commodities definition at Article 2(3)(c), and logistics under Article 2(3)(m) carries no such condition [1]. What did need work was title, because two contracts had it buying and reselling rather than handling for a principal. We rewrote them and the claim held.

The AED 340,000 side contract. A free zone manufacturer with clean qualifying revenue took a mainland services engagement worth AED 340,000, well inside what everyone assumed was a AED 5 million allowance. Total revenue was AED 5.8 million, so the cap was AED 290,000. The breach was found before the period closed and the work was restructured out in time. Found at audit, it would have cost five periods.

The company better off electing out. A free zone consultancy with AED 2.1 million of revenue had claimed QFZP status for two periods on the strength of a zone brochure. Consulting is not on the Article 2(1) list, so all its revenue was non-qualifying and the claim had never been valid. As an ordinary taxable person it had the AED 375,000 band, could elect Small Business Relief, and needed no audit [5]. It pays less tax outside the regime than inside it.

Get your QFZP position right before the FTA does

The 0% rate is real, and for a manufacturer, a genuine commodity trader, a logistics operator, a regulated fund manager or a group treasury company it is worth building a business around. What it is not is automatic. It is a conditional exemption you re-earn every period, priced with a five-period clawback, with a mandatory audit and no AED 375,000 buffer.

Since 2013, BusinessDubai.ae has completed 700+ company registrations across the UAE, including free zone companies structured for QFZP status and companies we deliberately advised not to claim it. We will test your activity mix against the closed list, model the QFZP route against the ordinary rate ladder and Small Business Relief on your numbers, structure the zone, premises and substance so the claim is defensible, and say plainly when a mainland licence is the better answer. Talk to a setup expert→ for a straight assessment rather than a brochure.

Frequently Asked Questions

What is a Qualifying Free Zone Person?

A Free Zone Person satisfying every condition in Article 18(1) in a given tax period, which gives 0% on Qualifying Income and 9% on other taxable income. Self-assessed per period [3].

Do all free zone companies pay 0% corporate tax in the UAE?

No. The 0% applies only to a QFZP's Qualifying Income. A free zone company failing the Article 18 conditions is an ordinary taxable person, taxed at 0% up to AED 375,000 and 9% above [3].

Is a free zone licence enough to get QFZP status?

No. You also need substance in the zone, income from the closed activity list, de minimis met, audited statements, transfer pricing compliance and no Article 19 election [1][3].

What happens if I fail a QFZP condition?

You cease to be a QFZP from the beginning of that tax period and for the subsequent four, under Article 18(2) and Article 5(2) of MD 229/2025 [1][3].

Do I really lose the status for four extra years?

Yes. Article 5(2) of MD 229/2025 says cessation runs from the beginning of the relevant tax period "and for the subsequent (4) four Tax Periods", and fixing the breach does not shorten it [1].

Which activities qualify for 0% as a QFZP?

The fourteen headings in Article 2(1) of MD 229/2025: manufacturing, processing, commodities trading, holding shares and securities, Ships, reinsurance, fund management, wealth management, headquarter and treasury services, aircraft leasing, Designated Zone distribution, logistics and ancillary activities [1].

Do consulting, marketing or IT services qualify?

No. The list is closed with no general services heading, and consulting, marketing, IT services, recruitment and general trading of non-commodity goods are absent [1].

Is there a catch-all for services in the list?

There is not. The only extension is activity (n), which Article 2(4) limits to activities necessary for, or making a minor contribution to, a main activity you already perform [1].

Does the 51% revenue test apply to logistics companies?

No. It sits inside the commodities trading definition at Article 2(3)(c) and does not attach to logistics under (m) or Designated Zone distribution under (l). This is widely misreported [1].

What are Qualifying Commodities?

Metals, minerals, energy and agricultural commodities in raw form, with the definition expressly excluding products packaged for retail sale. Price sourcing interacts with MD 230 of 2025 [1][7].

Can an unregulated wealth advisory firm claim 0%?

No. Headings (g) and (h) require regulatory oversight by the Competent Authority in the State: the Central Bank, DFSA, FSRA in ADGM, SCA or a Minister-designated body [1].

Are transactions with individuals excluded from the 0%?

Yes, as a rule. Article 2(2)(a) makes them an Excluded Activity, except those relating to Ships, fund management, wealth and investment management and Aircraft. Business-to-consumer models are therefore incompatible [1].

Can a QFZP earn rental income from property?

Only narrowly. Immovable property is an Excluded Activity, with one carve-back for Commercial Property in a Free Zone let to a Free Zone Person [1][2].

How does the de minimis rule work?

Non-qualifying revenue must not exceed 5% of total revenue or AED 5,000,000, whichever is lower. At AED 200 million of revenue the cap is AED 5 million [1][2].

What counts as non-qualifying revenue?

Revenue from Excluded Activities, revenue from non-Qualifying Activities where the counterparty is a non-Free Zone Person, and revenue from transactions with a Free Zone Person who is not the Beneficial Recipient [2].

What is excluded from the de minimis calculation entirely?

Under Article 4(3) of CD 100/2023, free zone property revenue, Permanent Establishment revenue and non-Qualifying IP revenue, all removed from both sides [2].

Does a QFZP get the AED 375,000 zero-rate band?

No. Article 3(1) gives ordinary taxable persons 0% up to AED 375,000, but Article 3(2) contains no threshold, so a QFZP pays 9% on non-qualifying taxable income from the first dirham [3].

So a non-QFZP free zone company gets the band but a QFZP does not?

Correct, and it is not a drafting error. A non-QFZP is an ordinary taxable person under Article 3(1); a QFZP trades the band for 0% on Qualifying Income under Article 3(2) [3].

Can a QFZP claim Small Business Relief?

No. Article 3(2) of Ministerial Decision No. 73 of 2023, as amended by Ministerial Decision 131 of 2026 states that a person electing the relief must not be a Qualifying Free Zone Person [5].

Is it ever better not to be a QFZP?

Often, for small companies whose activities are not on the list. Outside the regime you get the AED 375,000 band and Small Business Relief, avoid the audit, and carry no clawback risk [3][5].

When does Small Business Relief end?

It continues only for periods ending on or before 31 December 2029, and needs revenue at or below AED 3,000,000 in the relevant and all previous periods [5].

Do all Qualifying Free Zone Persons need audited financial statements?

Yes, regardless of size. Article 2(1) of Ministerial Decision No. 84 of 2025 has two limbs, and limb (b) covers Qualifying Free Zone Persons unconditionally [4].

Is the QFZP audit threshold really AED 50 million?

No. That belongs to limb (a) and applies to ordinary taxable persons, so any guide applying it to a QFZP has merged the two limbs of Article 2(1) [4].

Can failing to get audited cost me QFZP status?

Yes. Article 5(1)(b) of MD 229/2025 makes audited statements a condition of the status, so a missed audit can trigger the five-period disqualification under Article 5(2) [1].

What does adequate substance mean?

Under Article 8 of CD 100/2023, performing your Core Income Generating Activities in a Free Zone or Designated Zone with adequate assets, qualified full-time employees and operating expenditure, judged against your level of activities [2].

Can a QFZP outsource its core activities?

Yes. Ordinary CIGAs may go to another person in a Free Zone or Designated Zone with supervision retained; Qualifying IP CIGAs may go anywhere in the State or to a non-Related Party abroad [2].

Can I elect out of the QFZP regime, and back in?

You can elect out under Article 19, effective from the current or following tax period. There is no revocation mechanism, and Article 18(1)(c) makes not having elected a condition, so treat it as final [3].

How can a free zone company create a permanent establishment inside the UAE?

Through a fixed place of business or dependent agent on the mainland. Article 14 is applied reading "Qualifying Free Zone Person" for "Non-Resident Person" and areas outside the Free Zones for "State" [2][3].

Why do the 2025 rules apply to my 2023 and 2024 tax periods?

Because Article 7 of MD 229/2025 brings the decision, issued 28 August 2025, into effect on 1 June 2023, and Article 6 repealed MD 265/2023. Re-test filed positions [1].

Is the FTA's free zone corporate tax guide still reliable?

Partly. CTGFZP1 predates MD 229/2025 and MD 84/2025, so it misses the current activity list, the widened treasury wording and the unconditional audit rule [6].

References

[1] Ministry of Finance. Ministerial Decision No. 229 of 2025 Regarding Qualifying Activities and Excluded Activities, issued 28 August 2025. Art 2(1) the closed list; Art 2(2) Excluded Activities; Art 2(3) definitions, including the commodities heading at 2(3)(c) with its internal 51% test and the logistics definition at 2(3)(m) with no such condition; Art 2(4) ancillary; Art 3 de minimis; Art 5(1)(b) audited statements; Art 5(2) five-period cessation; Art 6 repealing MD 265/2023; Art 7 effect from 1 June 2023. MD 229 of 2025

[2] Ministry of Finance. Cabinet Decision No. 100 of 2023 on Determining Qualifying Income for the Qualifying Free Zone Person. Arts 3, 5 and 6 Qualifying Income and the PE and property carve-outs; Art 4 de minimis and the Art 4(3) exclusions; Art 8 substance, CIGAs and outsourcing; Art 10 repealing CD 55/2023. Cabinet Decision 100 of 2023

[3] Federal Tax Authority. Federal Decree-Law No. 47 of 2022. Art 3(1) ordinary rates with the AED 375,000 threshold from Cabinet Decision No. 116 of 2022; Art 3(2) QFZP rates with no threshold; Art 14 permanent establishment; Art 18(1) the five conditions; Arts 18(2) and 18(3) cessation and the Minister's power; Art 19 the election, with no revocation mechanism. Federal Decree-Law No. 47 of 2022

[4] Ministry of Finance. Ministerial Decision No. 84 of 2025 on Audited Financial Statements. Art 2(1) requires them from (a) a taxable person that is not a Tax Group with revenue exceeding AED 50,000,000 and (b) a Qualifying Free Zone Person, limb (b) standalone with no threshold. Applies from 1 January 2025, repealing MD 82/2023. Art 2(3) still cross-references the repealed MD 265/2023; no correcting amendment confirmed. MD 84 of 2025

[5] Ministry of Finance. Ministerial Decision No. 73 of 2023, as amended by Ministerial Decision 131 of 2026 on Small Business Relief. Revenue at or below AED 3,000,000 for the relevant and all previous periods; periods ending on or before 31 December 2029; Art 3(2) barring a QFZP from electing; Art 6 anti-abuse on artificial separation. MD 73 of 2023

[6] Federal Tax Authority. Corporate Tax Guide on Free Zone Persons (CTGFZP1), published around 26 May 2024. Predates MD 229/2025 and MD 84/2025, so it does not reflect the current activity list or the unconditional audit rule. FTA Free Zone Persons Guide CTGFZP1

[7] Ministry of Finance. Ministerial Decision No. 230 of 2025 on Recognised Price Reporting Agencies, the companion to MD 229/2025 on quoted prices for Qualifying Commodities. MD 230 of 2025

[8] Ministry of Finance. Cabinet Decision No. 55 of 2023 on Qualifying Income, repealed by Article 10 of Cabinet Decision No. 100 of 2023, both retroactive to 1 June 2023. Cited to explain the repeal. Cabinet Decision 55 of 2023