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May 15, 2026

This decision originally defined the Qualifying and Excluded Activities for Qualifying Free Zone Persons (QFZPs) under Cabinet Decision 55 of 2023. It established criteria for activities such as manufacturing, logistics, and headquarter services, and set the de minimis threshold for non-qualifying revenue at the lower of 5% of total revenue or AED 5 million. The decision also mandated the preparation of audited financial statements for QFZPs. Although it became effective on 1 June 2023, this decision was subsequently repealed in its entirety and replaced by Ministerial Decision No. 265 of 2023.

[Repealed by Ministerial Decision No. 265 of 2023]

This is not an Official Translation:

Regarding Qualifying Activities and Excluded Activities for the Purposes of Federal Decree Law No. 47 of 2022 on the Taxation of Corporations and Businesses

Ministerial Decision No. 139 of 2023

(Effective from 1 June 2023)

[GTL Notes]

Minister of State for Financial Affairs:

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. 8 of 2017 on Value Added Tax, 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,
Cabinet Decision No. 59 of 2017 on Designated Zones for the Purposes of the Federal Decree-Law No. 8 of 2017 on Value Added Tax,
Cabinet Decision No. 55 of 2023 on Determining Qualifying Income of the Qualifying Free Zone Person for the Purposes of Federal Decree Law No. 47 of 2022 on the Taxation of Corporations and Businesses,

Decided:

Article 1 - Definitions

Words and expressions in this Decision shall have the same meanings specified in the Federal Decree-Law No. 47 of 2022 ('Corporate Tax Law') and Cabinet Decision No. 55 of 2023 referred to above, and the following words and expressions shall have the meanings assigned against each:

Ship	:	Any structures normally operating, or set for operating in maritime navigation regardless of its power and tonnage.
Aircraft	:	Any machine that can derive support in the atmosphere from the reactions of the air other than the reactions of the air against the surface of the earth.
Designated Zone	:	A designated zone as defined in Federal Decree-Law No. 8 of 2017 referred to above, and which has been specified as a Free Zone for the purposes of the Corporate Tax Law.

Minister of State for Financial Affairs:

Decided:

Article 1 - Definitions

Article 2 - Qualifying Activities