UAE corporate tax, strategic before compliance.

What we do, and what we don't

What we do (strategic, not regulated)

• Pre-registration structural review: should the current corporate setup change before tax periods commence?
• Group structure analysis: holding companies, free zone vs mainland mix, related-party flows
• Qualifying Free Zone Person (QFZP) assessment: does the entity actually qualify, and is the income genuinely qualifying?
• Transfer pricing strategic positioning at the policy and structural level
• Small Business Relief evaluation: is it the right election for current circumstances and growth trajectory?
• Cross-jurisdictional structural questions: how does UAE corporate tax interact with other tax footprints the client retains?
• Briefing tax agents efficiently when execution work is needed

What we don't do (regulated activities — for licensed specialists)

• Filing corporate tax returns with the FTA
• Representing clients in FTA audits or correspondence
• Signing formal tax submissions or opinions
• Detailed transfer pricing documentation preparation
• Tax agent services as defined under UAE FTA registration requirements

The corporate tax framework in plain language

Headline rates

• 0% on taxable income up to AED 375,000 per tax period
• 9% on taxable income above AED 375,000
• 0% on qualifying income for Qualifying Free Zone Persons (subject to conditions)
• 15% Domestic Minimum Top-up Tax (DMTT) for large multinational groups (consolidated revenue > EUR 750 million) under Pillar Two, effective for financial years starting on or after 1 January 2025

Who's in scope

Corporate tax applies to all juridical persons incorporated, established, or otherwise registered in the UAE, including free zone entities. Natural persons conducting business in the UAE with turnover exceeding AED 1 million annually are also subject. Foreign entities with a permanent establishment in the UAE, or earning UAE-source income, are also potentially in scope.

Key dates

• 1 June 2023: First financial years subject to corporate tax
• 1 January 2024: Most calendar-year-end businesses' first tax period begins
• Within 9 months of tax-period end: Tax return and payment due (so a 31 December 2024 year-end has a deadline of 30 September 2025)
• 1 January 2025: Pillar Two DMTT effective for large MNE groups

The strategic questions worth asking

1. Should the corporate structure change before the next tax year?

Many UAE structures were set up when there was no corporate tax. Some patterns — multiple sub-entities for different lines of business, complex group structures with offshore holding companies — may no longer make sense. Restructuring is generally easier when there's no significant value to crystallise and no transactions that trigger gain recognition. We help clients identify whether restructuring is worth considering before tax compliance hardens around current structures.

2. Does your free zone status actually qualify?

The "0% on qualifying income" rule for Qualifying Free Zone Persons sounds simple. The conditions are not:

• The entity must be a QFZP, which requires maintaining adequate substance in the free zone
• Income must be "qualifying income" — which has specific defined categories (e.g., transactions with non-free zone persons generally don't qualify, with limited exceptions)
• The entity must comply with transfer pricing requirements
• Non-qualifying income is taxed at 9% — not 0%
• If a QFZP fails to meet conditions, it can lose QFZP status for that tax period and the following four tax periods (significant penalty)

We help clients honestly assess whether their free zone position holds up under scrutiny, and what changes may be needed to preserve 0% treatment on qualifying income.

3. Are you ready for transfer pricing obligations?

UAE corporate tax introduced transfer pricing requirements aligned with OECD principles. Related-party transactions must be at arm's length, and documentation requirements apply above certain thresholds. Many Dubai businesses with related-party flows — management charges from parents, intercompany loans, shared service arrangements — now face documented transfer pricing obligations they were previously unaware of.

4. Is Small Business Relief the right election?

Small Business Relief (SBR) under Ministerial Decision No. 73 of 2023 allows certain qualifying small businesses (revenue ≤ AED 3 million for the relevant and previous tax periods) to elect for an effective 0% rate for tax periods up to 31 December 2026. There are tradeoffs: SBR-electing businesses cannot carry forward tax losses or net interest expenses from those periods. For a fast-growing business approaching the threshold, the decision matters and is worth thinking through before electing.

5. How do UAE rules interact with your other tax footprints?

HNW individuals and businesses with operations in multiple jurisdictions face interaction questions: UAE corporate tax vs UK corporation tax, treaty positions, controlled foreign company rules in home countries, beneficial ownership reporting in EU jurisdictions. Strategic advisory is most useful when these interactions need framing before engaging multiple jurisdiction-specific tax specialists.

How a typical engagement runs

Discovery (free, 30 minutes)

We understand your current structure, your tax footprint across jurisdictions, your growth trajectory, and the specific questions you're sitting with. Honest assessment of whether strategic advisory adds value.

Strategic review (paid engagement)

Written strategic review covering: structural assessment, free zone position (if applicable), Small Business Relief evaluation (if relevant), transfer pricing exposure, recommended next steps. Document is yours to keep regardless of what you do next.

Specialist coordination

Where formal tax-agent work is required — registration, returns, audit response, formal opinions — we coordinate with FTA-registered tax agents we work with. Selection based on case complexity and client fit; commercial arrangements (if any) disclosed in writing before introduction.

Ongoing strategic advisory (optional)

Quarterly or annual review for clients who want continuing strategic oversight as their business evolves and as UAE tax law continues to develop. The FTA continues to publish clarifications and ministerial decisions; positions that work today may need refinement tomorrow.