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UAE Free Zone Corporate Tax Rules Clarified: What Businesses Need to Know in 2026

In a transformative move for the UAE’s business landscape, the long-standing operational barrier between Dubai’s Free Zones and its Mainland is dissolving. Under Executive Council Resolution No. 11 of 2025, certain companies operating in Free Zones can now apply for permits to conduct business directly within mainland Dubai. 

This landmark regulation, issued by the Government of Dubai and managed by the Department of Economy and Tourism (DET), fundamentally changes how Free Zone Establishments (FZEs) and Free Zone Companies (FZCOs) interact with the local market. For founders, startups, and SMEs, this offers an unparalleled opportunity for regional growth and operational simplification. 

Understanding the Context

When the UAE introduced the federal corporate tax regime in 2023, free zone businesses were initially promised continued benefits under certain conditions. However, many grey areas remained — particularly around what counts as qualifying income, economic substance, and interactions with mainland entities. 

The 2025 Ministerial Decisions resolve this uncertainty. They provide specific rules, definitions, and compliance requirements, ensuring transparency and consistency across all free zones in the country. 

Key Highlights of Ministerial Decisions No. 229 & 230 (2025)

The Ministry’s rulings bring clarity in three critical areas that determine whether a business can continue enjoying 0% corporate tax. 

1.Qualifying Activities Defined

Only specific types of business activities will continue to enjoy the 0% tax rate. These typically include: 

  • Manufacturing, processing, and re-export of goods within free zones. 
  • Holding company activities with qualifying income. 
  • Commodity trading under recognised price benchmarks. 
  • Services provided exclusively between qualifying free-zone entities. 

 

2.Recognised Price Reporting for Commodity Traders

  • Companies engaged in commodity trading must now adhere to internationally recognised pricing benchmarks (such as Platts or LME) to determine fair value. 
    This ensures transparency and alignment with global transfer pricing and anti-profit shifting standards. 

3.Economic Substance Requirement Strengthened

  • Businesses must now demonstrate genuine operations within the UAE. This includes: 

    • A physical presence (office or warehouse). 
    • Local employees or active management based in the UAE. 
    • Board meetings and management decisions made in the UAE. 
    • Proper documentation of business activities, leases, and employment records. 

    These substance tests ensure that only real, active businesses — not shell entities — can continue to benefit from tax exemptions.

Expanded Scope of Qualifying Commodity Trading

The UAE has expanded the definition of commodity trading to include new, sustainability-linked categories: 

  • Industrial chemicals 
  • Environmental commodities (like carbon credits and energy certificates) 
  • Secondary and by-product materials 

This expansion supports the UAE’s Green Economy Vision 2030 and reflects the country’s growing focus on sustainable and circular economy sectors

Who Still Qualifies for 0% Corporate Tax?

Qualifying Activity 

Tax Rate 

Key Conditions 

Manufacturing, re-export, and distribution 

0% 

Must be conducted within a free zone 

Holding company operations 

0% 

Income must be from qualifying sources 

Commodity trading (expanded categories) 

0% 

Subject to recognised price benchmarks 

Services between free-zone entities 

0% 

Must meet economic substance criteria 

What Doesn’t Qualify for 0% Corporate Tax

  • Mainland-derived income, unless within approved frameworks or structures. 
  • Passive income (e.g., dividends, interest, or royalties) without sufficient UAE presence. 
  • Non-qualifying business activities that don’t appear on the Ministry’s approved list. 
  • Paper entities or companies lacking real operational substance. 

Pros and Cons of the New Free Zone Tax Clarifications

Pros 

  • Regulatory clarity: Businesses can now plan tax strategies with confidence. 
  • Fair competition: Only companies with real economic activities benefit, reducing misuse of free zones. 
  • Global credibility: Aligns UAE’s tax framework with OECD and international transparency standards. 
  • Encouragement of innovation: The inclusion of sustainable commodities supports green business growth. 

⚠️ Cons 

  • Higher compliance requirements: Businesses must maintain detailed documentation and evidence of substance. 
  • Reduced flexibility: Entities working with both mainland and free zone clients may face complex reporting. 
  • Potential tax exposure: Non-qualifying income could attract a standard 9% corporate tax rate. 
  • Operational costs: Smaller entities may need to increase their local footprint to maintain eligibility. 

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