UAE compliance · Federal Tax Authority

The rate is two lines. The return is your ledger.

Nought per cent to AED 375,000 and nine above it — the part everyone can recite. Taxable income starts from accounting profit under IFRS and is adjusted from there, which makes the general ledger the working papers for a federal filing. That is the part that changes how a finance system has to be built.

A reference, not a determination. This sets out what the regime requires and what it means inside NetSuite. Whether your entity qualifies as a free zone person, whether a payment is at arm’s length, and what your adjustment schedule contains are judgements on your facts — take them with your tax adviser.

113days — last tax period end for small business relief31 December 2026

Last reviewed

The rates

Four of them, and three are conditional.

The regime applies to financial years beginning on or after 1 June 2023, so a calendar-year business entered it on 1 January 2024 and a June year end entered it on 1 July 2023. Which rate applies is rarely the question; whether the conditions attached to it hold is.

0%

On taxable income up to AED 375,000

Every taxable person

A band, not an exemption — the business still registers and still files.

9%

On taxable income above AED 375,000

The standard rate

Applied to the excess over the threshold, not to the whole of taxable income.

0% / 9%

Qualifying and non-qualifying income

A qualifying free zone person

Conditional on maintaining QFZP status, and lost for the tax period and the four that follow if it fails.

15%

Domestic minimum top-up tax

Multinational groups with consolidated revenue of EUR 750 million or more in at least two of the four preceding financial years

For financial years starting on or after 1 January 2025, where the effective rate in the UAE falls below 15%.

What the regime actually requires

Six things that are not the rate.

01

Taxable income starts from accounting profit

The return begins with the accounting net profit in financial statements prepared under IFRS, and applies a schedule of adjustments to it. There is no separate tax ledger to maintain and no reconciliation to a parallel set of books — which means the general ledger has become the working papers for a federal tax filing, and the standard it has to meet went up on the day the regime started.

02

Registration is universal, and separate from liability

Every taxable person registers, including free zone entities and businesses whose income sits entirely inside the 0% band. Registration is not triggered by owing tax. The timeframes were set by licence issuance month under FTA Decision No. 3 of 2024, and the penalty for missing them is AED 10,000 — payable by businesses that owe no tax at all.

03

Your deadline is your own

There is no national filing date. The return and the payment are both due nine months after the end of the tax period, so a December year end files by 30 September and a June year end by 31 March. A group whose subsidiaries have not been aligned to one financial year has several deadlines rather than one, and each of them is a separate filing.

04

The free zone 0% is conditional, not a status you hold

A qualifying free zone person pays 0% on qualifying income and 9% on the rest. Qualifying income is defined by Cabinet Decision No. 100 of 2023, and the de minimis test allows non-qualifying revenue of up to 5% of total revenue or AED 5 million, whichever is lower. Breach it, or fail the substance requirements, and QFZP status goes for that tax period and the four following it. That is a five-year consequence for one year of transactions.

05

Transfer pricing reaches domestic transactions too

The arm’s length principle applies to related parties and connected persons, and it does not stop at the border. Payments to owners and to their other businesses are inside it. Master file and local file documentation is required where the taxable person’s revenue is AED 200 million or more, or where it belongs to a multinational group with consolidated revenue of AED 3.15 billion or more.

06

Small business relief is elective, and it ends

A resident person with revenue of AED 3 million or less may elect to be treated as having no taxable income. It is claimed in the return rather than granted automatically, it is lost permanently once revenue exceeds the threshold in any period, and it is available only for tax periods ending on or before 31 December 2026. Electing also forfeits carried-forward losses and disallowed interest from that period.

Administrative penalties

  • Late registrationAED 10,000
  • Late filing, first twelve monthsAED 500 per month
  • Late filing, from the thirteenth monthAED 1,000 per month
  • Late payment14% per annum, accruing monthly

Late registration is charged to businesses that owe no tax, which is the one most often discovered after the fact. The FTA has run a waiver initiative cancelling or refunding it where the first return is filed within seven months of the end of the first tax period — check whether it still applies before assuming either way.

Inside NetSuite

What has to be true before the return is assembled.

None of this is filing software. It is the configuration and the data that decide whether the return can be produced from the system at all, or whether it is rebuilt in a spreadsheet every year by someone reading transaction descriptions.

01

The chart of accounts is now a tax document

Adjustments are only as good as the accounts they are computed from.

  • Non-deductible items — entertainment, fines, and the disallowed share of interest — need to be identifiable in the ledger rather than extracted from it by someone reading descriptions.
  • Entertainment expenditure is deductible at 50%, so it has to be separable from the general expense line it usually hides inside.
  • Depreciation, provisions and impairments all sit in the adjustment schedule, and each has to trace back to a posting rather than to a spreadsheet.

02

Related party transactions have to be identifiable as such

Transfer pricing documentation is assembled from the ledger or it is not assembled at all.

  • Related parties and connected persons flagged on the customer and vendor records, so intercompany and owner transactions can be extracted rather than remembered.
  • Transactions with connected persons — owners and their relatives, and businesses they control — captured with the same discipline as intercompany ones, because the rule does not distinguish them.
  • Domestic related party transactions included. The instinct that transfer pricing is a cross-border problem is what leaves the largest gap in a UAE group.

03

Free zone entities need their revenue split at transaction level

The de minimis test is a revenue ratio, and a ratio needs a numerator you can produce.

  • Qualifying and non-qualifying revenue distinguished on the transaction, not inferred from the customer or reconstructed at year end.
  • The 5% or AED 5 million test monitored during the year, because by the time it is breached the consequence has already attached to the period.
  • Mainland branches of free zone entities kept separable, since their income is outside qualifying income regardless of what the head office does.

04

Groups multiply the filings unless they are aligned

A tax group is an election with conditions, not a consequence of ownership.

  • Financial years aligned across subsidiaries, or each entity carries its own nine-month deadline on its own calendar.
  • A tax group requires 95% ownership and shared financial year, and a free zone entity claiming QFZP status cannot be in one — so the group structure and the free zone position have to be decided together.
  • Where entities file separately, intercompany eliminations that were only ever a consolidation exercise become transactions each side has to support.

Sources

  1. Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses — UAE Ministry of Finance, 2022
  2. Corporate tax — rates, scope and exempt persons — The Official Platform of the UAE Government
  3. Cabinet Decision No. 100 of 2023 — qualifying income for a qualifying free zone person (repealing Cabinet Decision No. 55 of 2023) — UAE Federal Tax Authority, 2023
  4. Cabinet Decision No. 142 of 2024 — top-up tax on multinational enterprises — UAE Federal Tax Authority, 2024
  5. Domestic minimum top-up tax — UAE Ministry of Finance
  6. Ministerial Decision No. 73 of 2023 — small business relief — UAE Ministry of Finance, 2023
  7. Small Business Relief — corporate tax guide (CTGSBR1) — UAE Federal Tax Authority, 2023
  8. Ministerial Decision No. 97 of 2023 — transfer pricing documentation requirements — UAE Ministry of Finance, 2023
  9. Ministerial Decision No. 126 of 2023 — general interest deduction limitation rule — UAE Ministry of Finance, 2023
  10. Interest Deduction Limitation Rules — corporate tax guide (CTGIDL1) — UAE Federal Tax Authority, 2025
  11. FTA Decision No. 3 of 2024 — timeline for corporate tax registration — UAE Federal Tax Authority, 2024
  12. Returns and payment due within nine months from the end of the tax period — UAE Federal Tax Authority

Cabinet Decision No. 55 of 2023 is cited widely and is repealed. Qualifying income for a free zone person is determined by Cabinet Decision No. 100 of 2023, which is what the free zone material above rests on.

The first hard return is the one after the relief ends.

A business that has elected small business relief since 2023 has filed returns with no adjustment schedule behind them. The period after 31 December 2026 is the first that needs one, and the ledger it will be built from is the ledger being posted to now.