22 August 2026 · Register & file
Free Zone Registration & Filing
A 0% rate is not a pass on compliance. Every free zone company — QFZP or not — must register for corporate tax on EmaraTax, maintain audited financial statements, comply with transfer pricing rules on related-party dealings, and file a corporate tax return within nine months of its financial year-end, reporting its qualifying and non-qualifying income separately and confirming its QFZP position. Missing registration carries a flat AED 10,000 penalty regardless of company size, and audited accounts are themselves a QFZP condition — since Ministerial Decision No. 84 of 2025, every Qualifying Free Zone Person must have audited financial statements with no revenue threshold, so an unaudited year is a breach on its own, independent of anything else in the income analysis.
Exiloz Management & Tax Consultant · Dubai-based FTA-focused advisory · VAT, corporate tax & accounting
Zero rate, full registration
Being a QFZP does not remove the registration or filing duty — if anything, free zone companies face closer scrutiny precisely because they are claiming a 0% outcome. Registration, audited accounts and transfer pricing compliance sit alongside the income and substance tests as conditions of the regime, not optional extras.
- Register for corporate tax on EmaraTax and obtain your tax registration number.
- Late registration carries a flat AED 10,000 administrative penalty.
- Audited financial statements are a QFZP condition for every free zone person, at any revenue size.
- Transfer pricing rules apply to related-party dealings, including disclosure with the return.
- Register even if you expect all income to sit at 0% — the rate does not remove the duty.
- A new free zone entity should register as soon as it has a licence, not wait for its first return.
What the return must show
The corporate tax return is where you evidence and defend the 0% position, not just where you report a number. A return that simply states 0% without the underlying qualifying and non-qualifying split and supporting analysis is an invitation for an FTA query.
- File within nine months of the financial year-end, the same deadline as mainland companies.
- Report qualifying and non-qualifying income separately, with the classification behind each.
- Confirm the de minimis limits are respected for the period being reported.
- Disclose related-party transactions and transfer pricing positions where required.
- Keep the supporting analysis and evidence file in case of FTA review, even after filing.
Why every QFZP needs audited financials
Since Ministerial Decision No. 84 of 2025, applying to tax periods starting on or after 1 January 2025, every Qualifying Free Zone Person must prepare audited financial statements — there is no revenue threshold that exempts smaller free zone companies. An unaudited year is itself a breach of the QFZP conditions, independent of what the income and substance analysis shows, so it can cost the 0% rate even on a company that otherwise qualifies cleanly.
- No revenue threshold applies — the audit condition covers every QFZP, however small.
- The audit must finish in time to support the nine-month filing deadline, not be rushed afterwards.
- An unaudited year is a standalone breach, separate from the income and de minimis tests.
- Book the audit early in the compliance calendar; it is now as fundamental to the 0% rate as substance.
Getting the order of operations right
Free zone compliance is not a single year-end task — it is a sequence with its own deadlines, and leaving everything until the ninth month invites mistakes. Registration should happen as soon as the entity is licensed, the audit should be scheduled well before the financial year closes, transfer pricing documentation should be ready to produce on request, and the return itself should be the last, well-supported step rather than a scramble.
- Register on EmaraTax immediately after incorporation, not close to a deadline.
- Schedule the audit early enough that it finishes with time to spare before the nine-month filing deadline.
- Keep transfer pricing master file and local file documentation ready to produce on FTA request.
- File the corporate tax return only once the qualifying and non-qualifying classification and the audit are both finalised.
Related guides
Frequently Asked Questions
For free zone companies handling registration, audit and filing in the same compliance cycle.
Do free zone companies have to register for corporate tax?
Yes. Even a QFZP on 0% must register on EmaraTax, keep audited accounts and file a return. The 0% rate is a reward for meeting the QFZP conditions, not an exemption from the registration and filing obligations that apply to every taxable person.
Do I need audited accounts?
Yes. Audited financial statements are one of the conditions to be a Qualifying Free Zone Person, and since Ministerial Decision No. 84 of 2025 there is no revenue threshold — every QFZP needs them, regardless of size.
When is the return due?
Within nine months of the end of your financial year, the same deadline that applies to mainland companies. The audit and transfer pricing documentation need to be ready well before that date, not on it.
What penalty applies for late registration?
A flat AED 10,000 administrative penalty applies for late corporate tax registration, regardless of the company's size or income, so registering promptly after incorporation is worth doing even before the first accounting period closes.
Do I need transfer pricing documentation every year?
Transfer pricing rules apply to related-party dealings on an ongoing basis, and documentation should be maintained and disclosed with the return where required, even in years where the underlying transactions have not changed much from the year before.
What if our audit is not finished by the filing deadline?
The audit needs to be scheduled early enough to finish before the nine-month deadline, because the return should be built on finalised, audited figures. Leaving the audit until close to the deadline is one of the most common causes of a late or unsupported filing.
Does 0% mean no paperwork?
The opposite, in practice. A QFZP typically carries more documentation than a standard 9% mainland company, because it must evidence every condition behind the 0% claim — registration, substance, audited accounts, transfer pricing and the qualifying/non-qualifying split all have to be on file.
Can Exiloz handle our free zone filing?
Yes. We register you on EmaraTax, arrange and manage the audit, prepare the transfer pricing documentation, and file the return with the qualifying and non-qualifying position fully documented.
Stay compliant at 0%
Exiloz registers, arranges the audit, prepares transfer pricing documentation and files for your free zone company — building the evidence file that supports your 0% position from day one, not just at filing time.