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May 15, 2026

This decision specifies Qualifying and Excluded Activities for Qualifying Free Zone Persons (QFZPs) under Federal Decree-Law 47 of 2022 and Cabinet Decision 100 of 2023. Key Qualifying Activities include manufacturing and fund management. Critically, it introduces detailed provisions for calculating Qualifying Income from Qualifying Intellectual Property. The decision establishes the de minimis threshold for non-qualifying revenue (lower of 5% or AED 5 million) and mandates QFZPs prepare audited financial statements. As its most crucial action, this decision repeals and replaces the earlier Ministerial Decision 139 of 2023, providing greater clarity.

[Repealed by Ministerial Decision No. 229 of 2025]
[Repeals Ministerial Decision No. 139 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. 265 of 2023

Issued 27 Oct 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 Law No. 6 of 2007 on the Organization of Insurance Operations, 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,
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, 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,
Ministerial Decision No. 139 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,

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.