UAE Corporate Tax (2023)
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The UAE introduced a federal Corporate Tax (CT) regime effective for financial years beginning on or after 1 June 2023 — marking a historic shift for a country previously known as a zero-tax jurisdiction. The UAE CT rates are: 0% on taxable income up to AED 375,000 (to support SMEs); 9% on taxable income above AED 375,000. Free zone companies that meet specific conditions can qualify as Qualifying Free Zone Persons (QFZPs) and continue to benefit from 0% CT on their qualifying income while paying 9% on non-qualifying income. The Pillar Two global minimum tax framework (BEPS) applies from 2025 for large multinationals with global revenue exceeding EUR 750 million — subject to a top-up tax to 15% if the effective rate on UAE income falls below this floor. The Small Business Relief allows businesses with revenue below AED 3 million (for tax periods ending before or on 31 December 2026) to elect to not pay CT. Key exemptions include income from UAE government entities, extractive businesses (oil and gas under specific regimes), qualifying investment funds, and regulated investment entities. The CT law aligns with international standards including OECD transfer pricing and the arm's length principle. UAE businesses must now register for CT, file annual returns, and maintain proper documentation — a significant compliance change for the region.
Corporate Tax = 0% on first AED 375,000 taxable income + 9% on taxable income above AED 375,000; Qualifying Free Zone Person: 0% on qualifying income, 9% on non-qualifying income; Pillar Two top-up (multinationals): 15% floor − effective UAE rate
- 1Determine whether the entity is subject to UAE CT: UAE mainland entities, free zone companies (QFZPs have special rates), permanent establishments of foreign companies in UAE.
- 2Calculate taxable income: start from accounting profit, then apply specific CT adjustments (non-deductible expenses, exempt income, loss carry-forwards, interest limitation rules).
- 3Apply the Small Business Relief if eligible: revenue below AED 3M for specified periods — the entity is treated as having zero taxable income.
- 4For free zone entities: determine which income is 'qualifying' (derived from free zone to free zone transactions or specific qualifying activities) and which is non-qualifying (mainland transactions, passive income below certain thresholds).
- 5Apply tax rates: 0% on first AED 375,000; 9% on the rest. For QFZPs: 0% on qualifying; 9% on non-qualifying.
- 6For large multinationals (revenue > EUR 750M globally): assess whether the UAE effective CT rate meets the 15% global minimum. If not, a Domestic Minimum Top-Up Tax (DMTT) applies from 2025.
- 7File the CT return via the FTA's EmaraTax portal within 9 months of the financial year-end. Pay CT by the filing deadline.
The 0% band on first AED 375,000 means many SMEs pay no CT.
Taxable income AED 250,000 falls entirely within the 0% band. CT liability: nil. Additionally, with revenue AED 2,800,000 (below AED 3M threshold), Small Business Relief election is available — the entity can elect to treat taxable income as nil for this period.
Effective rate: 6.75% (101,250 / 1,500,000) — well below statutory 9% due to 0% band.
First AED 375,000: AED 0. Remaining AED 1,125,000 × 9% = AED 101,250. Total CT: AED 101,250. Effective rate: 6.75%. The 0% band on first AED 375,000 reduces the effective rate for all but the largest businesses.
QFZPs maintain 0% on qualifying income — a key advantage of maintaining free zone status.
Qualifying income (AED 5M) is taxed at 0%. Non-qualifying income (AED 500K) is subject to CT at standard rates. However, AED 500K - AED 375K = AED 125K × 9% = AED 11,250. Total CT: AED 11,250. The QFZP must carefully track qualifying vs non-qualifying income.
Multinationals above EUR 750M global revenue must meet 15% global minimum from 2025.
This multinational's UAE effective rate (9% on income above AED 375K, but with exemptions and reliefs it may fall to ~4% effective) is below the 15% Pillar Two minimum. The UAE DMTT requires a top-up of 11% × AED 50M = AED 5.5M to bring the effective rate to 15%.
UAE businesses calculating first-year CT liability and determining if Small Business Relief applies., where accurate uae corporate tax analysis through the Uae Corporate Tax supports evidence-based decision-making and quantitative rigor in professional workflows
Free zone companies assessing whether they qualify as QFZPs and segregating qualifying vs non-qualifying income., where accurate uae corporate tax analysis through the Uae Corporate Tax supports evidence-based decision-making and quantitative rigor in professional workflows
Multinationals with UAE operations assessing Pillar Two exposure and UAE effective tax rate calculations., where accurate uae corporate tax analysis through the Uae Corporate Tax supports evidence-based decision-making and quantitative rigor in professional workflows
Corporate tax advisers advising clients on group structures, participation exemptions, and Tax Group formation., where accurate uae corporate tax analysis through the Uae Corporate Tax supports evidence-based decision-making and quantitative rigor in professional workflows
Finance directors modeling UAE CT impact on financial statements and setting up CT compliance processes.
Oil and Gas Companies
UAE oil and gas companies operated under emirate-level tax decrees before CT was introduced. These companies continue to be subject to the emirate-level regimes (e.g., Abu Dhabi tax decree imposing 50–85% effective rates on oil company profits). They are excluded from the federal 9% CT regime and remain under their specific concession agreements.
Dividend and Capital Gains Participation Exemption
The UAE CT law provides a Participation Exemption: dividends received from qualifying subsidiaries and capital gains on qualifying shareholdings are exempt from UAE CT. To qualify, the UAE holding company must own at least 5% of the subsidiary for at least 12 months. This makes UAE an attractive holding company jurisdiction.
Natural Person Business Income
Natural persons (individuals) conducting business in UAE are subject to CT if their business income exceeds AED 1 million annually. Personal investment income (salaries, dividends, interest on personal accounts) is not subject to CT. The AED 1 million threshold protects individual investors and small operators.
Tax Groups
UAE parent companies can form a Tax Group with wholly owned UAE subsidiaries, allowing group-level tax filing and the ability to offset group losses against group profits. Requirements include 95%+ common ownership, all entities having the same financial year-end, and all being UAE tax residents.
| Taxable Income / Entity Type | CT Rate |
|---|---|
| Taxable income 0 – AED 375,000 | 0% |
| Taxable income above AED 375,000 | 9% |
| QFZP — Qualifying Free Zone Income | 0% |
| QFZP — Non-Qualifying Income | Standard rates (0%/9%) |
| Small Business Relief (revenue < AED 3M) | Elective — treat as zero taxable income |
| Extractive businesses (oil/gas) | Governed by pre-CT emirate-level regimes |
| Pillar Two top-up (global revenue > EUR 750M) | Up to 15% effective minimum |
When did UAE Corporate Tax start?
UAE Corporate Tax applies to financial years beginning on or after 1 June 2023. A company with a June-to-May financial year would have had its first UAE CT year start on 1 June 2023. A company with a January-to-December financial year would have its first UAE CT year start on 1 January 2024.
What is the UAE CT rate?
0% on taxable income up to AED 375,000; 9% on taxable income above AED 375,000. Free zone Qualifying Free Zone Persons (QFZPs) pay 0% on qualifying income. Large multinationals may be subject to an additional Domestic Minimum Top-Up Tax (DMTT) from 2025 to meet the 15% Pillar Two global minimum.
Are free zone companies exempt from UAE Corporate Tax?
Free zone companies that qualify as Qualifying Free Zone Persons (QFZPs) can benefit from 0% CT on qualifying income. However, they must meet strict conditions including maintaining 'adequate substance' in the free zone. Non-qualifying income is subject to the standard 9% CT rate. Not all free zone companies automatically qualify.
What is the Small Business Relief?
Small Business Relief allows businesses with annual revenue below AED 3 million (for financial years ending before or on 31 December 2026) to elect to be treated as having zero taxable income. This relieves small businesses from complex CT compliance. The election must be made each year. This is particularly important in the context of uae corporate tax calculations, where accuracy directly impacts decision-making. Professionals across multiple industries rely on precise uae corporate tax computations to validate assumptions, optimize processes, and ensure compliance with applicable standards. Understanding the underlying methodology helps users interpret results correctly and identify when additional analysis may be warranted.
Can UAE CT losses be carried forward?
Yes. UAE CT losses can be carried forward indefinitely and offset against future taxable income. The annual offset is limited to 75% of taxable income for any given year (allowing only partial loss absorption per year). Losses from tax groups can be transferred between group members subject to specific conditions.
What are transfer pricing requirements under UAE CT?
UAE CT requires all transactions between related parties to be conducted at arm's length (market price). Businesses must maintain transfer pricing documentation. The FTA can adjust transfer prices to arm's length if the actual prices deviate. Master file and local file requirements apply to large groups based on revenue thresholds.
Is there withholding tax under UAE CT?
The UAE CT law does not introduce a general withholding tax on dividends, interest, or royalties paid to non-residents. Existing special economic zones and specific regimes have their own rules. This means UAE remains an attractive holding company location as outbound payments are generally not subject to UAE withholding tax.
What is the Pillar Two / DMTT?
The OECD Pillar Two (Global Anti-Base Erosion Rules) sets a 15% global minimum effective tax rate for large multinationals with global revenue over EUR 750 million. The UAE introduced the Domestic Minimum Top-Up Tax (DMTT) from 2025 to collect this top-up tax in the UAE before other countries can claim it — consistent with UAE retaining sovereignty over its tax base.
プロのヒント
UAE businesses with related-party transactions should establish transfer pricing policies and documentation before their first CT filing year. The FTA can impose penalties for inadequate documentation even where the final tax position is correct. Starting documentation early is significantly less costly than reconstructing it later.
ご存知でしたか？
The UAE's introduction of Corporate Tax in 2023 was driven partly by international pressure from OECD/G20's global minimum tax initiative (Pillar Two). By introducing CT itself at 9%, the UAE ensured it retained sovereignty over taxing its businesses rather than having other countries (like France or Germany) 'top up' UAE companies' tax under the 15% global minimum. The 9% rate was deliberately set below 15% but above zero.