Understanding UAE Corporate Tax
A solid understanding of the corporate tax framework helps you work more productively with your advisor and make informed business decisions.
Who Is Taxable?
UAE corporate tax applies to three categories of persons. Resident juridical persons — all companies incorporated in the UAE, plus foreign companies effectively managed and controlled from the UAE. Resident natural persons — individuals conducting business in the UAE with annual turnover exceeding AED 1 million. Non-resident persons — foreign entities with a permanent establishment in the UAE or earning UAE-sourced income.
Calculating Taxable Income
Taxable income starts with accounting profit under IFRS and is adjusted for corporate tax purposes. Key adjustments include adding back non-deductible expenses (fines, penalties, donations above limits, entertainment beyond the allowable percentage), subtracting exempt income (qualifying dividends from UAE and foreign subsidiaries, capital gains on qualifying shareholdings), and applying transfer pricing adjustments for related-party transactions that do not meet the arm's length standard.
The Free Zone Regime
Qualifying free zone persons benefit from a 0% rate on qualifying income — but the conditions are strict. You must be a juridical person incorporated in a free zone, maintain adequate substance (employees, assets, expenditure), derive qualifying income from qualifying activities or transactions with other free zone persons, comply with transfer pricing rules, prepare audited financial statements, and not have elected to be subject to the standard rate. Non-qualifying income is taxed at 9%, and breaching the de minimis threshold (more than 5% or AED 5 million of non-qualifying revenue) can jeopardize the 0% rate on all income.
Small Business Relief
Businesses with revenue not exceeding AED 3 million in the current and all previous tax periods can elect for small business relief, treating their taxable income as zero. This is not available to qualifying free zone persons, members of multinational groups with consolidated revenue exceeding EUR 750 million, or persons who have previously exceeded the threshold. Critically, losses from relief periods cannot be carried forward.
Tax Groups
Two or more UAE resident juridical persons can form a tax group if the parent owns at least 95% (directly or indirectly), all members are UAE tax residents, have the same financial year, and prepare financial statements in the same currency. The group files a single return, offsets profits and losses between members, and eliminates intra-group transactions. This can provide significant cash flow and administrative benefits.
Transfer Pricing
All related-party transactions must comply with the arm's length principle, consistent with OECD Transfer Pricing Guidelines. Documentation requirements include a master file (group-level information), local file (entity-level analysis of related-party transactions), and country-by-country report for groups with consolidated revenue exceeding AED 3.15 billion. The FTA can adjust taxable income if transfer prices do not reflect arm's length conditions.