Website Last updated:

May 15, 2026

Cabinet Decision (CD) No. 100 of 2023 repealed CD 55/2023, refining Free Zone Corporate Tax rules for Qualifying Free Zone Persons (QFZPs) effective June 1, 2023. This updated framework included significant scope expansions. 'Core Income-Generating Activities (CIGA)' must now be undertaken in a 'Free Zone or a Designated Zone'. Crucially, CD 100 recognized 'Qualifying Intellectual Property (QIP)' income, encompassing Patents and Copyrighted Software (excluding trademarks), as a separate category of Qualifying Income. Furthermore, CIGA related to QIP received specialized rules, permitting outsourcing to any Person in the State or to Non-Related Parties outside the State, provided adequate supervision is maintained. Income from local immovable property transactions remains taxable.

[Repeals Cabinet Decision No. 55 of 2023]

This is not an Official Translation:

Determining Qualifying Income for the Qualifying Free Zone Person for the Purposes of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses

Cabinet Decision No. 100 of 2023

Issued 25 Oct 2023 - (Effective from 1 June 2023)

[GTL Notes]

The Cabinet has decided:

Having reviewed the Constitution,
Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses,
Cabinet Decision No. 55 of 2023 on Determining Qualifying Income for the Qualifying Free Zone Person for the Purposes of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses, and
Pursuant to what was presented by the Minister of Finance and upon the approval of the Cabinet.

Article 1 - Definitions

Definitions in Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses shall apply to this Decision, otherwise the following words and expressions shall have the meaning assigned against each, unless the context requires otherwise: