When the UAE introduced Corporate Tax, the most asked question from Free Zone businesses was: does it apply to us? Yes — but with a conditional 0% rate. Understanding the distinction is the foundation of CT compliance for every Free Zone entity.
Qualifying vs Non-Qualifying Income
Income Type
Qualifying 0%?
Notes
Transactions with other QFZP entities
Yes
Core qualifying income
Exports outside UAE
Yes
Must be documented
Qualifying activity income
Yes
Manufacturing, logistics, shipping etc.
Sales to UAE mainland
No
Taxable at 9% — can breach de minimis
De minimis non-qualifying income
Limited
5% of total revenue or AED 5M (lower)
QFZP Conditions — All Must Be Met
▸Established in a Qualifying Free Zone
▸Adequate substance — real employees, premises, decisions
▸Qualifying income only (or within de minimis threshold)
▸No election to be subject to standard 9% CT
▸Audited financial statements prepared in accordance with IFRS
▸Transfer pricing at arm’s length with documentation
Client Case Illustration
A JAFZA-registered technology company generated incidental mainland revenue not monitored against the de minimis threshold. Univia confirmed the 0% qualifying rate was at risk and implemented a revenue restructuring recommendation before the tax period closed, preserving QFZP status for the full year.
Every engagement at Univia is led by a qualified expert — FCCA, CPA, or specialist-certified. No junior handoffs. No guesswork. Just senior-led advisory that delivers.