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May 15, 2026

This decision defines 'Qualifying Income' for a Qualifying Free Zone Person (QFZP). It includes income from transactions with other Free Zone Persons and income from 'Qualifying Activities' with Non-Free Zone Persons. A cornerstone requirement is that the QFZP must undertake its core income-generating activities and maintain adequate substance (assets, qualified employees, operating expenditure) in the Free Zone. Income attributable to a Domestic or Foreign Permanent Establishment, or from certain immovable property transactions, constitutes 'Excluded Activities' and is taxed at the standard rate. The decision also details the de minimis requirements for including other income.

[Repealed by Cabinet Decision No. 100 of 2023]

This is not an official Translation:

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

Cabinet Decision No. 55 of 2023

Issued 30 May 2023 – (Effective from 1 June 2023)

[GTL Notes]

The Cabinet:

Having reviewed the Constitution,
Federal Law No. 1 of 1972 on the Competencies of Ministries and Powers of the Ministers, and its amendments,
Federal Decree-Law No. 13 of 2016 on the Establishment of the Federal Tax Authority, and its amendments,
Federal Decree-Law No. 28 of 2022 on Tax Procedures,
Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses,
Pursuant to what was presented by the Minister of Finance and upon the approval of the Cabinet,

Decided:

Article 1 - Definitions

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

Domestic Permanent Establishment	:	A place of business or other form of presence of a Qualifying Free Zone Person outside the Free Zone in the State.
Qualifying Activities	:	Any activities determined by a decision issued by the Minister and conducted by a Qualifying Free Zone Person from which Qualifying Income is derived.
Excluded Activities	:	Any activities determined by a decision issued by the Minister and conducted by a Qualifying Free Zone Person from which non-Qualifying Income is derived.
Non-Free Zone Person	:	Any Person who is not a Free Zone Person.
Commercial Property	:	Immovable property or part thereof: used exclusively for a Business or Business Activity. not used as a place of residence or accommodation including hotels, motels, bed and breakfast establishments, serviced apartments and the like
Corporate Tax Law	:	Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses.

Article 2 - Scope of Application

The provisions of this Decision shall apply to Qualifying Free Zone Persons.

The Cabinet:

Decided:

Article 1 - Definitions

Article 2 - Scope of Application

Article 3 - Qualifying Income