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May 15, 2026

This Decision, implementing Cabinet Decision No. 100 of 2023, specifies the updated list of Qualifying and Excluded Activities for Qualifying Free Zone Persons (QFZPs). It notably expands the definitions for 'Qualifying Commodities' and 'Trading of Qualifying Commodities' in Articles 1 and 2 to include structured financing. The Decision reaffirms the de minimis requirements in Article 3 and clarifies in Article 5 that QFZP status requires meeting conditions under Corporate Tax Law and preparing audited financial statements per Ministerial Decision No. 84 of 2025. It formally repeals the preceding Ministerial Decision 265 of 2023.

[Repeals Ministerial Decision No. 265 of 2023]

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. 229 of 2025

Issued: 28 Aug 2025 - (Effective from 1 June 2023)

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. 14 of 2018 Regarding the Central Bank and Organization of Financial Institutions and Activities, and its amendments,
Federal Decree-Law No. 28 of 2022 on Tax Procedures, and its amendments,
Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses, and its amendments,
Federal Decree-Law No. 48 of 2023 on the Regulation of Insurance Activities,
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, and its amendments,
Cabinet Decision No. 100 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,
Cabinet Decision No. 119 of 2024 Approving the Schedule of the Integrated Customs Tariff in Accordance to the Harmonized System of Classification and Coding of Goods for the Cooperation Council for the Arab States of the Gulf (2022) and its updates,
Ministerial Decision No. 265 of 2023 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. 84 of 2025 on Audited Financial Statements for the Purposes of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses,

Decided:

Article 1 - Definitions

Definitions in Federal Decree-Law No. 47 of 2022 and Cabinet Decision No. 100 of 2023 referred to above shall apply to this Decision, otherwise the following words and expressions shall have the meaning assigned against each, unless the context requires otherwise.