Free Zones & QFZP (0%)
Cabinet Decision No. 55/2023 & Ministerial Decision No. 139/2023 on Qualifying Free Zone Persons, 0% Qualifying Income, De Minimis, and adequate substance.
Statutory Topics in this Category (51)
Qualifying Free Zone Person (QFZP) 0% Eligibility Conditions
Must maintain adequate substance, derive qualifying income, avoid disqualifying elections, and comply with TP.
Adequate Substance Requirements in UAE Free Zones
Entity must have adequate full-time staff, physical office in Free Zone, and local operating expenditure.
Qualifying Income Definition under Ministerial Decision No. 139
Income derived from transactions with other Free Zone persons and designated qualifying activities.
De Minimis Requirement Calculation (5% or AED 5,000,000)
Non-qualifying revenue must not exceed the lower of 5% of total revenue or AED 5,000,000.
Mandatory Audited Financial Statements for QFZP
QFZP must prepare and maintain audited financial statements under IFRS regardless of revenue level.
Manufacturing of Goods or Materials in Free Zone
Qualifying activity: transforming raw materials or manufacturing industrial products inside Free Zone.
Holding of Shares and Other Securities in Free Zone
Holding shares and securities for investment purposes is a 0% qualifying activity for Free Zone entities.
Ship Ownership, Management and Operation (0%)
Shipping operations, international maritime transport, and crew management qualify for 0% CT.
Reinsurance Services Regulated Activity (0%)
Reinsurance services under competent regulatory authority oversight qualify for 0% tax.
Fund Management Services Subject to Regulatory Oversight
Fund management services provided by regulated Free Zone managers qualify for 0% tax.
Wealth and Investment Management Services (0%)
Regulated wealth management services qualify for 0% corporate tax for Free Zone persons.
Headquarter Services to Related Parties (0%)
Providing strategic planning, risk control, and executive management to related group entities.
Treasury and Financing Services to Related Parties (0%)
Intra-group loans, cash pooling, and interest hedging services qualify for 0% tax.
Financing and Leasing of Aircraft (0%)
Aviation leasing, financing, and related engines leasing qualify for 0% qualifying income.
Distribution of Goods or Materials in or from a Designated Zone
Wholesale trading and distribution of goods via Designated Zones qualifies for 0% rate.
Logistics Services Performed in Free Zones (0%)
Warehousing, freight consolidation, and inventory distribution qualify for 0% CT.
Excluded Activities: Commercial Banking Transactions
Transactions with natural persons and retail banking automatically trigger 9% CT.
Excluded Activities: Insurance and Takaful Services
Direct insurance underwriting (other than reinsurance) is an excluded activity taxed at 9%.
Excluded Activities: Natural Resource Extraction
Extractive operations conducted by Free Zone entities are excluded from QFZP 0% status.
Commercial Property in Free Zone vs Residential Property
Income from Free Zone commercial real estate qualifies for 0%; residential real estate is 9%.
Transactions with Mainland UAE Customers (9% Rule)
Selling goods/services directly to UAE mainland businesses without Designated Zone entails 9% CT.
Designated Zones vs Non-Designated Free Zones List
Fenced free zones with customs control qualify as Designated Zones for distribution benefits.
Loss of QFZP Status: 5-Year Disqualification Penalty
Violating QFZP criteria revokes 0% status for the current year and the subsequent 4 years (5 years total).
Outsourcing Core Income Generating Activities (CIGA)
CIGA may be outsourced only to related parties or third parties physically located in the Free Zone.
Election to be Subject to Standard 9% Rate
Free Zone entity may voluntarily opt out of QFZP status to benefit from group relief or SBR.
Meydan Free Zone 0% Tax Strategy & Licensing
Compliance standard under Cabinet Decision No. 55/2023 regarding Free Zone tax operations and QFZP eligibility.
DMCC Free Zone Commodity Trading Tax Framework
Compliance standard under MD No. 139/2023 regarding Free Zone tax operations and QFZP eligibility.
DIFC Financial Free Zone Corporate Tax Application
Compliance standard under DIFC Tax Enactment 2024 regarding Free Zone tax operations and QFZP eligibility.
ADGM Abu Dhabi Global Market Tax Regulations
Compliance standard under ADGM Commercial Regs regarding Free Zone tax operations and QFZP eligibility.
DAFZA Dubai Airport Freezone Distribution Hub Rules
Compliance standard under Cabinet Decision No. 59/2017 regarding Free Zone tax operations and QFZP eligibility.
JAFZA Jebel Ali Free Zone Industrial Tax Status
Compliance standard under JAFZA Free Zone Regs regarding Free Zone tax operations and QFZP eligibility.
IFZA International Free Zone Authority Compliance
Compliance standard under IFZA Tax Guidelines regarding Free Zone tax operations and QFZP eligibility.
Shams Sharjah Media City Intellectual Property Rules
Compliance standard under Cabinet Decision No. 55/2023 regarding Free Zone tax operations and QFZP eligibility.
RAKEZ Ras Al Khaimah Economic Zone Manufacturing
Compliance standard under RAKEZ Authority Rules regarding Free Zone tax operations and QFZP eligibility.
KIZAD Abu Dhabi Industrial Zone Customs Benefits
Compliance standard under Cabinet Decision No. 59/2017 regarding Free Zone tax operations and QFZP eligibility.
Free Zone Virtual Assets Service Providers (VASP)
Compliance standard under VARA Regulations 2024 regarding Free Zone tax operations and QFZP eligibility.
Free Zone Holding Companies Dividend Repatriation
Compliance standard under Federal Decree-Law No. 47/2022 regarding Free Zone tax operations and QFZP eligibility.
Intellectual Property Qualifying vs Non-Qualifying Income
Compliance standard under OECD Nexus Approach & MD 139 regarding Free Zone tax operations and QFZP eligibility.
Free Zone Flexi-Desk & Virtual Office Substance Risks
Compliance standard under Cabinet Decision No. 55/2023 regarding Free Zone tax operations and QFZP eligibility.
Free Zone Resident Visa Quota & Payroll Substantiation
Compliance standard under Cabinet Decision No. 55/2023 regarding Free Zone tax operations and QFZP eligibility.
High Seas Shipping & International Freight Services
Compliance standard under MD No. 139/2023, Art. 2 regarding Free Zone tax operations and QFZP eligibility.
Aircraft Engine Maintenance & Overhaul in Free Zones
Compliance standard under MD No. 139/2023, Art. 2 regarding Free Zone tax operations and QFZP eligibility.
Designated Zone Storage of Third-Party Goods
Compliance standard under Cabinet Decision No. 59/2017 regarding Free Zone tax operations and QFZP eligibility.
Free Zone Software Development & IT Services Status
Compliance standard under Ministerial Decision No. 139/2023 regarding Free Zone tax operations and QFZP eligibility.
Free Zone Marketing & Consulting Services to Overseas Clients
Compliance standard under MD No. 139/2023 regarding Free Zone tax operations and QFZP eligibility.
Free Zone eCommerce B2C Transactions Corporate Tax
Compliance standard under Cabinet Decision No. 55/2023 regarding Free Zone tax operations and QFZP eligibility.
Free Zone B2B Wholesale Trading of Raw Materials
Compliance standard under MD No. 139/2023 regarding Free Zone tax operations and QFZP eligibility.
Free Zone Re-Invoicing Centers & Substance Scrutiny
Compliance standard under FTA Corporate Tax Guide regarding Free Zone tax operations and QFZP eligibility.
Free Zone Intercompany Financing Margin Benchmark
Compliance standard under FTA Transfer Pricing Guide regarding Free Zone tax operations and QFZP eligibility.
Free Zone Dual License (Branch on Mainland) Taxation
Compliance standard under Federal Decree-Law No. 47/2022 regarding Free Zone tax operations and QFZP eligibility.
Dual License Free Zone & Mainland Branch Tax Segregation
Free zone entity operating mainland branch must segregate income; mainland branch is taxed at standard 9%.
Have Questions Regarding Free Zones & QFZP (0%)?
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