UAE free zone 0% corporate tax qualifying income 2026
  • 07 July, 2026
  • Corporate Tax

Your free zone licence is not a 0% tax guarantee

Many Dubai founders assume a free zone company automatically pays 0% corporate tax. It does not. The 0% rate only applies to a Qualifying Free Zone Person (QFZP) on its qualifying income. Miss one QFZP condition, or let your non-qualifying income breach the de minimis limit, and the entire company is taxed at 9% for that year — not just the offending slice. This guide sets out exactly what keeps your 0% rate intact in 2026.

The 2026 amendments did not create a blanket free zone exemption. Free zone entities face the same documentation, transfer pricing and audit standards as everyone else — the 0% rate is a reward for meeting strict conditions, not a birthright of the licence.

The QFZP Conditions — All of Them Must Hold

  • Adequate substance: real people, premises and operating costs in the free zone.
  • Qualifying income: derived within the qualifying-activity and beneficial-recipient rules.
  • De minimis limits respected: non-qualifying income kept under the threshold.
  • No election to be taxed at 9%: you have not opted into the standard regime.
  • Audited accounts & transfer pricing: audited financial statements and TP compliance.

Fail any single condition and you are not a QFZP for that tax period. The consequence is severe: the whole entity is taxed at 9%, and the disqualification can extend to later years.

The De Minimis Rule at a Glance

TestLimit
Non-qualifying revenue as % of total revenueUnder 5%
Non-qualifying revenue absolute capUnder AED 5M
Which appliesThe lower of the two
If you breach either9% on all income

Qualifying vs Excluded Income

Qualifying income broadly includes income from other free zone persons (as beneficial recipient) and income from qualifying activities such as manufacturing, qualifying-commodity trading, holding of shares, and fund or treasury services. Excluded income — most banking and insurance, income from immovable property (with limited commercial-property exceptions), and transactions with natural persons — is taxed at 9% no matter how strong your substance is.

How to Protect Your 0% Rate in 2026

  1. Classify every revenue stream as qualifying, excluded or non-qualifying.
  2. Track non-qualifying revenue live against the 5% / AED 5M limit — not at year-end.
  3. Evidence your substance with staff, premises and expenditure in the zone.
  4. Keep audited accounts and TP files current, since both are QFZP conditions.
  5. Model borderline mainland work before you accept it, so one deal does not sink the rate.

Keep Your Free Zone 0% Rate

Exiloz tests your QFZP conditions, classifies your income and monitors your de minimis headroom. See our corporate tax service or talk to a consultant today.

Frequently Asked Questions

Is free zone income automatically 0%?

No. You must be a Qualifying Free Zone Person and the income must be qualifying income. Fail a condition or breach the de minimis limit and the whole entity is taxed at 9%.


What is the de minimis rule?

Non-qualifying revenue must stay under the lower of 5% of total revenue or AED 5 million. Cross either and you lose QFZP status for the period.


What counts as qualifying income?

Income from other free zone persons (as beneficial recipient) and from qualifying activities. Excluded activities, PE income and most property income do not qualify.


What happens if I lose QFZP status?

The entire entity is taxed at 9% for that period, and the disqualification can extend to following years.