How UAE Free Zone Firms Can Capitalise on 0% Corporate Tax
The United Arab Emirates (UAE) has long been recognised as a global business hub, attracting entrepreneurs and corporations with its strategic location, state-of-the-art infrastructure, and investor-friendly policies. A cornerstone of this appeal is the nation’s favourable corporate tax environment, particularly within its numerous free zones. These designated areas offer a suite of benefits designed to stimulate economic growth and diversification.
Central to the allure of UAE free zones is the 0% Corporate Tax rate available to entities that meet specific criteria. This tax incentive is not merely a financial boon; it serves as a catalyst for innovation, competitiveness, and international investment. By alleviating the tax burden, the 0% Corporate Tax policy empowers businesses to reinvest profits, expand operations, and contribute more significantly to the UAE’s dynamic economy.
However, accessing and maintaining this tax advantage requires a thorough understanding of the regulatory framework. Companies must navigate a complex landscape of eligibility requirements, compliance obligations, and strategic considerations. Failure to adhere to these stipulations can result in the forfeiture of tax benefits and potential financial penalties.
This article aims to demystify the 0% Corporate Tax regime for UAE free zone companies. We will explore the intricacies of qualifying as a Free Zone Person, delineate between qualifying and non-qualifying income, and examine the operational standards necessary to sustain tax-exempt status. Additionally, we will provide actionable insights into structuring your business to maximise tax benefits while ensuring full compliance with UAE corporate tax laws.
By delving into these topics, we intend to equip business owners and stakeholders with the knowledge required to capitalise on the 0% Corporate Tax opportunity effectively. Understanding and leveraging these tax incentives can be a pivotal factor in achieving long-term business success in the UAE’s competitive market.
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Understanding the 0% Corporate Tax Regime in UAE Free Zones
The United Arab Emirates (UAE) has strategically positioned itself as a global business hub, offering a range of incentives to attract foreign investment. Central to this strategy are the UAE free zones, which provide a unique environment for businesses to thrive.
Definition and Purpose of Free Zones in the UAE
UAE free zones are specially designated areas that offer businesses a host of benefits, including 100% foreign ownership, full repatriation of profits, and exemption from import and export duties. These zones are designed to facilitate international business by providing streamlined administrative processes and state-of-the-art infrastructure. Each free zone caters to specific industries, such as technology, media, healthcare, and logistics, allowing businesses to operate within a community of like-minded enterprises.
Historical Context and Evolution of the 0% Corporate Tax Policy
The concept of free zones in the UAE dates back to the 1980s, with the establishment of the Jebel Ali Free Zone (JAFZA) in 1985. This initiative marked a significant shift in the UAE’s economic policy, moving away from oil dependency towards diversification. The success of JAFZA led to the proliferation of over 40 free zones across the UAE, each offering various tax incentives to attract foreign investment.
In 2023, the UAE introduced a federal corporate tax regime, setting a standard corporate tax rate of 9%. However, to maintain the attractiveness of free zones, the government allowed qualifying free zone entities to continue benefiting from a 0% corporate tax rate on qualifying income. This move underscores the UAE’s commitment to fostering a competitive business environment.
Key Objectives: Attracting Foreign Investment and Promoting Economic Diversification
The 0% Corporate Tax policy in UAE free zones serves multiple strategic objectives:
- Attracting Foreign Investment: By offering tax-free incentives, the UAE positions itself as an attractive destination for international businesses seeking to establish a presence in the Middle East. The ability to operate without the burden of corporate taxes allows companies to reinvest profits and expand operations.
- Promoting Economic Diversification: The UAE aims to reduce its reliance on oil revenues by developing other sectors of the economy. Free zones play a crucial role in this diversification strategy by encouraging growth in industries such as technology, finance, and logistics.
- Enhancing Global Competitiveness: The tax incentives offered in free zones help the UAE compete with other global business hubs, attracting multinational corporations and fostering innovation.
The 0% Corporate Tax regime in UAE free zones is a testament to the country’s forward-thinking economic policies. By understanding the structure and benefits of these zones, businesses can strategically position themselves to capitalise on the opportunities available. The combination of tax incentives, robust infrastructure, and a business-friendly environment makes UAE free zones an ideal choice for companies aiming for growth and international expansion.
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Eligibility Criteria for 0% Corporate Tax in Free Zones
To benefit from the UAE’s 0% Corporate Tax regime, businesses operating within free zones must meet specific eligibility criteria. These requirements ensure that only entities contributing substantively to the UAE’s economic landscape can access these tax incentives.
Definition of a Qualifying Free Zone Person (QFZP)
1. Adequate Substance: Physical Presence, Staff, and Operational Expenditure
A QFZP must demonstrate substantial economic presence within the free zone. This includes:
- Physical Presence: Maintaining a tangible office space within the free zone.
- Staffing: Employing adequate personnel to conduct core income-generating activities.
- Operational Expenditure: Incuring sufficient operating expenses commensurate with the nature and scale of activities.
These requirements ensure that the entity’s operations are genuinely based in the UAE, aligning with the principle of adequate substance.
2. Qualifying Income Sources
To benefit from the 0% Corporate Tax rate, a QFZP must derive income from qualifying activities, such as:
- Transactions with other free zone entities.
- Export of goods or services.
- Certain regulated financial services.
Income from non-qualifying activities, like transactions with UAE mainland entities, may be subject to the standard 9% tax rate.
3. Compliance with Transfer Pricing and Arm’s Length Principles
QFZPs must adhere to transfer pricing regulations, ensuring that transactions with related parties are conducted at arm’s length. This involves:
- Documenting all related-party transactions.
- Maintaining transfer pricing documentation to substantiate the pricing of such transactions.
Compliance with these principles prevents profit shifting and ensures fair taxation.
4. Maintenance of Audited Financial Statements
QFZPs are required to prepare and maintain audited financial statements, regardless of revenue thresholds. This ensures transparency and accuracy in financial reporting, aligning with international best practices.
Implications of Non-Compliance
Failure to meet the above criteria can lead to significant consequences:
- Transition to 9% Tax Rate: The entity may lose its QFZP status, subjecting all income to the standard corporate tax rate.
- Penalties: Non-compliance can result in financial penalties and increased scrutiny from tax authorities.
Maintaining compliance is crucial to continue benefiting from the 0% Corporate Tax regime.
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Qualifying vs. Non-Qualifying Income: Navigating the De Minimis Rule
The UAE’s 0% Corporate Tax regime offers significant advantages for businesses operating within free zones. However, to maintain this benefit, companies must understand the distinction between qualifying and non-qualifying income and adhere to the de minimis threshold.
Qualifying Income: The Foundation of Tax Benefits
Qualifying income refers to revenue generated from specific activities that align with the objectives of the UAE’s free zones. These activities typically include:
- Transactions with other free zone entities: Engaging in business with companies also operating within UAE free zones.
- Export of goods or services: Providing products or services to clients outside the UAE.
- Certain regulated financial services: Offering financial services that meet regulatory standards within the free zone framework.
Engaging in these qualifying activities ensures that the income remains subject to the 0% Corporate Tax rate, reinforcing the benefits of operating within a UAE free zone.
Non-Qualifying Income: Activities That Risk Tax Status
Non-qualifying income arises from activities that fall outside the scope of approved free zone operations. These include:
- Transactions with UAE mainland entities: Conducting business with companies based outside the free zones within the UAE.
- Excluded activities: Engaging in sectors or operations explicitly excluded from the free zone’s permitted activities.
Generating non-qualifying income can jeopardize a company’s eligibility for the 0% Corporate Tax rate, making it imperative to monitor and manage such income streams carefully.
Understanding the De Minimis Threshold
The de minimis threshold is a critical parameter that determines the extent to which a company can earn non-qualifying income without losing its tax-exempt status. Specifically, a Qualifying Free Zone Person (QFZP) must ensure that its non-qualifying income does not exceed:
- 5% of total revenue, or
- AED 5 million,
whichever is lower, within a given tax period.
Exceeding this threshold results in the loss of QFZP status, subjecting the company to the standard 9% corporate tax rate on all income for the current and subsequent four tax periods.
Strategies to Manage and Monitor Income Streams
To maintain compliance with the de minimis threshold and preserve the benefits of the 0% Corporate Tax rate, companies should implement the following strategies:
- Regular Financial Monitoring: Establish robust accounting practices to track income sources accurately, distinguishing between qualifying and non-qualifying income.
- Strategic Business Planning: Prioritize activities that generate qualifying income and limit engagements that may lead to non-qualifying income.
- Consultation with Tax Professionals: Engage with tax advisors to understand the implications of various income streams and ensure compliance with the de minimis threshold.
- Periodic Compliance Reviews: Conduct regular audits to assess adherence to the de minimis requirements and make necessary adjustments proactively.
By implementing these strategies, companies can effectively manage their income streams, ensuring continued eligibility for the 0% Corporate Tax rate within UAE free zones.
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Maintaining Adequate Substance: Operational Requirements
To benefit from the UAE’s 0% Corporate Tax regime, free zone companies must demonstrate substantial economic presence within the UAE. This requirement ensures that businesses are not merely registered in the UAE for tax advantages but are actively contributing to the local economy.
Importance of Demonstrating Substantial Economic Presence
The UAE’s Economic Substance Regulations (ESR) mandate that entities engaged in Relevant Activities must maintain adequate substance in the UAE. This includes having a physical presence, qualified personnel, and incurring operational expenditures. Compliance with these requirements is crucial to retain the benefits of the 0% Corporate Tax rate.
Key Components of Adequate Substance
Physical Office Space
A tangible office space within the free zone is essential. This office should be appropriate for the nature and scale of the business activities conducted. Virtual offices or shared workspaces may not satisfy the ESR requirements. Maintaining official records, such as meeting minutes and accounting records, at the physical office further substantiates the entity’s presence.
Qualified Personnel
Employing an adequate number of qualified employees who are physically present in the UAE is a critical component. These employees should be involved in the core income-generating activities of the business. The level of staffing should align with the scale and nature of the business operations.
Operational Expenditures Aligned with Business Activities
Entities must incur sufficient operating expenditures in the UAE, commensurate with their business activities. This includes expenses related to office rent, employee salaries, utilities, and other operational costs. The expenditures should reflect the actual economic activities conducted within the UAE.
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Outsourcing Considerations: Ensuring Control and Supervision
While certain activities can be outsourced, the entity must retain control and supervision over these outsourced functions. The service providers should be located within the UAE, and the entity must demonstrate that it has the ability to monitor and control the outsourced activities effectively. This ensures that the core income-generating activities remain under the entity’s purview, satisfying the ESR requirements.
Risks of Inadequate Substance
Failure to meet the economic substance requirements can lead to significant consequences:
- Potential Audits: Non-compliant entities may be subject to audits by the regulatory authorities to assess their adherence to the ESR.
- Penalties: Non-compliance can result in financial penalties, which may be substantial depending on the severity and duration of the non-compliance.
- Loss of Tax Benefits: Entities that fail to demonstrate adequate substance risk losing their Qualifying Free Zone Person status, thereby becoming subject to the standard corporate tax rate.
Maintaining adequate substance is not only a regulatory requirement but also a strategic imperative to sustain the benefits of the 0% Corporate Tax regime.
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Strategic Business Structuring to Maximise 0% Corporate Tax Benefits
The UAE’s 0% Corporate Tax regime offers significant advantages for businesses operating within designated free zones. However, to fully capitalise on these benefits, companies must adopt strategic business structuring that aligns with regulatory requirements and ensures compliance.
Segregating Qualifying and Non-Qualifying Activities into Separate Entities
To maintain eligibility for the 0% Corporate Tax rate, businesses should segregate qualifying and non-qualifying activities into distinct legal entities. This separation ensures that non-qualifying income does not jeopardise the tax-exempt status of qualifying activities. For instance, a company can establish one entity within a designated free zone to handle qualifying activities, such as exporting goods, and another entity outside the free zone for non-qualifying activities, like domestic sales.
This approach not only facilitates compliance with the de minimis threshold but also simplifies financial reporting and auditing processes. By clearly delineating income streams, businesses can effectively manage their tax obligations and avoid unintended breaches of tax regulations.
Utilising Designated Zones for Trading Activities to Maintain Eligibility
Designated free zones in the UAE offer specific advantages for trading activities, particularly concerning the 0% Corporate Tax rate. By operating within these zones, businesses can conduct qualifying trading activities, such as exporting goods, while benefiting from tax exemptions.
It’s essential to verify that the chosen free zone is officially designated under UAE tax regulations. Operating within a designated zone ensures that trading activities align with the criteria for qualifying income, thereby maintaining eligibility for the 0% Corporate Tax rate.
Implementing Robust KYC Procedures for Trading Operations
Know Your Customer (KYC) compliance is a critical component of maintaining eligibility for the 0% Corporate Tax rate. Implementing robust KYC procedures ensures that all trading operations are conducted with verified and legitimate partners, reducing the risk of engaging in prohibited or non-qualifying activities.
Effective KYC measures include:
- Conducting thorough background checks on clients and suppliers.
- Maintaining comprehensive records of all transactions.
- Regularly updating client information to reflect any changes.
By adhering to stringent KYC protocols, businesses can demonstrate compliance with regulatory standards and safeguard their tax-exempt status.
Regular Compliance Reviews and Audits to Ensure Ongoing Eligibility
Regular compliance reviews and audits are essential to ensure that business operations continue to meet the criteria for the 0% Corporate Tax rate. These reviews should assess:
- Adherence to qualifying activity requirements.
- Compliance with the de minimis threshold for non-qualifying income.
- Maintenance of adequate economic substance within the free zone.
Engaging external auditors or consultants can provide an objective assessment of compliance status and identify areas for improvement. Proactive compliance management mitigates the risk of penalties and ensures the continuity of tax benefits.
Case Studies: Successful Structuring Examples
Case Study 1: TechExport LLC
TechExport LLC, a technology firm, established its operations within a designated free zone to export software solutions globally. By focusing exclusively on qualifying activities and maintaining adequate substance, the company successfully leveraged the 0% Corporate Tax rate. Regular compliance audits ensured ongoing eligibility and facilitated international expansion.
Case Study 2: TradeMasters FZCO
TradeMasters FZCO operates within a designated free zone, handling the import and export of consumer goods. The company implemented rigorous KYC procedures and segregated its domestic sales through a separate mainland entity. This strategic structuring allowed TradeMasters to benefit from tax exemptions on qualifying income while maintaining compliance with UAE tax regulations.
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Compliance and Documentation: Staying on the Right Side of the Law
For UAE free zone companies aiming to benefit from the 0% Corporate Tax regime, meticulous compliance and comprehensive documentation are paramount. Adhering to the Federal Tax Authority’s (FTA) requirements not only safeguards tax-exempt status but also fortifies the company’s reputation and operational integrity.
Mandatory Documentation: Ensuring Transparency and Accountability
Maintaining accurate and up-to-date records is a cornerstone of tax compliance. The FTA mandates specific documentation to substantiate a company’s eligibility for the 0% Corporate Tax rate:
- Audited Financial Statements: Companies must prepare and retain audited financial statements that reflect their financial activities accurately. These statements serve as evidence of the company’s economic substance and operational presence within the free zone.
- Transfer Pricing Documentation: Entities engaged in transactions with related parties are required to maintain comprehensive transfer pricing documentation. This includes a Master File and a Local File, detailing the nature of transactions, pricing methodologies, and compliance with the arm’s length principle. Such documentation ensures transparency and aligns with international tax standards.
- Records of Qualifying Income and Activities: Companies must keep detailed records distinguishing between qualifying and non-qualifying income. This segregation is crucial for demonstrating adherence to the de minimis threshold and maintaining tax-exempt status.
By diligently maintaining these documents, businesses can substantiate their compliance with the 0% Corporate Tax requirements and be prepared for any FTA audits or inquiries.
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Role of the Federal Tax Authority (FTA) in Enforcement
The FTA plays a pivotal role in monitoring and enforcing corporate tax compliance. It conducts audits, reviews submitted documentation, and ensures that companies adhere to the established tax laws and regulations. The FTA’s oversight ensures a fair and transparent tax environment, reinforcing the integrity of the 0% Corporate Tax regime.
Importance of Timely and Accurate Record-Keeping
Timely and precise record-keeping is not merely a regulatory requirement but a strategic business practice. It enables companies to:
- Demonstrate Compliance: Accurate records provide evidence of adherence to tax laws and eligibility criteria for the 0% Corporate Tax rate.
- Facilitate Audits: Well-maintained documentation simplifies the audit process, reducing the risk of disputes or penalties.
- Inform Decision-Making: Comprehensive records offer insights into financial performance, aiding strategic planning and operational efficiency.
Implementing robust record-keeping systems and regularly updating documentation ensures that companies remain compliant and responsive to regulatory requirements.
Potential Consequences of Non-Compliance
Failure to comply with corporate tax obligations can lead to significant repercussions:
- Fines: Non-compliance may result in financial penalties, including fines for late filing, inadequate documentation, or inaccurate reporting.
- Back Taxes: Companies found to be non-compliant may be liable for back taxes, negating the benefits of the 0% Corporate Tax rate.
- Reputational Damage: Non-compliance can tarnish a company’s reputation, affecting relationships with stakeholders and potential investors.
To mitigate these risks, companies should prioritize compliance, seek professional tax advice, and stay informed about regulatory changes.
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Leveraging 0% Corporate Tax for International Expansion
The United Arab Emirates (UAE) offers a compelling proposition for businesses aiming for international expansion, notably through its 0% Corporate Tax regime in designated free zones. This tax incentive is pivotal in attracting foreign investment and facilitating global business strategies.
Attracting Foreign Investment through 0% Corporate Tax
The 0% Corporate Tax rate in UAE free zones serves as a significant draw for foreign investors. By eliminating corporate tax on qualifying income, the UAE provides an environment conducive to profit maximization and reinvestment. This tax benefit, coupled with 100% foreign ownership and exemption from import/export duties, positions the UAE as a strategic hub for international business operations. Such incentives are instrumental in fostering foreign investment and promoting economic diversification.
Opportunities for UK Businesses in UAE Free Zones
UK businesses seeking to expand their global footprint can capitalize on the advantages offered by UAE free zones. Establishing operations in these zones allows UK companies to benefit from the 0% Corporate Tax rate on qualifying income, thereby enhancing their competitive edge. Additionally, the UAE’s strategic location serves as a gateway to markets in the Middle East, Africa, and Asia, facilitating broader international reach. The streamlined setup processes and robust infrastructure in UAE free zones further support UK businesses in establishing a strong presence in the region.
Benefits for UAE Free Zone Companies Expanding into the UK Market
Conversely, UAE free zone companies looking to penetrate the UK market can leverage their tax-efficient base to offer competitive pricing and invest in market development. The cost savings realized from the 0% Corporate Tax regime can be redirected towards market research, marketing initiatives, and establishing local partnerships in the UK. This strategic allocation of resources enhances the potential for successful market entry and sustained growth in the UK.
Strategic Positioning and Global Growth
The 0% Corporate Tax framework in UAE free zones is not merely a fiscal advantage but a strategic tool for global expansion. By reducing tax liabilities, businesses can allocate more resources towards innovation, talent acquisition, and market expansion. This tax incentive supports companies in building resilient and scalable business models, essential for competing in the global marketplace. Moreover, the UAE’s commitment to maintaining a business-friendly environment reinforces its position as a preferred destination for companies pursuing international growth strategies.
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Conclusion:
The UAE’s 0% Corporate Tax regime for Qualifying Free Zone Persons (QFZPs) offers substantial tax benefits, positioning the nation as a premier destination for global business operations. This favourable tax environment is designed to attract foreign investment and stimulate economic growth.
To fully leverage these tax benefits, businesses must adhere to specific compliance requirements. Key obligations include maintaining adequate economic substance within the free zone, ensuring that core income-generating activities are conducted in the UAE, and keeping comprehensive records of qualifying income and activities. Additionally, companies must comply with transfer pricing regulations and maintain audited financial statements to substantiate their tax positions.
Strategic tax planning is essential to navigate the complexities of the 0% Corporate Tax regime. This involves segregating qualifying and non-qualifying activities, utilising designated zones for eligible operations, and implementing robust KYC procedures. Regular compliance reviews and audits further ensure ongoing eligibility and mitigate the risk of non-compliance.
Given the intricate nature of the UAE’s corporate tax landscape, seeking professional advice is highly recommended. Tax experts can provide tailored guidance to optimise tax benefits, ensure compliance with the Federal Tax Authority’s regulations, and develop effective strategic tax planning initiatives.
In conclusion, while the 0% Corporate Tax regime presents significant opportunities, it necessitates diligent compliance and strategic foresight. By proactively managing tax obligations and seeking expert counsel, businesses can maximise their tax benefits and contribute to the UAE’s dynamic economic environment.
To fully capitalize on the UAE’s 0% Corporate Tax regime, it’s essential to navigate the complexities of business setup and tax compliance with expert guidance. AlfaZone UAE offers comprehensive tax consultancy and business setup assistance, ensuring your venture aligns with all regulatory requirements.
For personalized support, contact AlfaZone UAE:
- Phone: +971 4 341 3190
- Email: [email protected]
- Office: Office 101, Clover Bay Tower, Marasi Drive, Business Bay, Dubai
- Website: alfazoneuae.com
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Frequently Asked Questions (FAQs) on How UAE Free Zone Firms Can Capitalise on 0% Corporate Tax
A QFZP is a juridical person (company or branch) incorporated or registered in a UAE Free Zone that meets specific conditions to benefit from a 0% corporate tax rate on qualifying income.
To be a QFZP, an entity must:
Be a Free Zone person.
Maintain adequate substance in the Free Zone.
Derive qualifying income.
Not have elected to be subject to the standard UAE corporate tax regime.
Comply with transfer pricing rules and documentation requirements.
Ensure non-qualifying revenue does not exceed the de minimis threshold.
Prepare audited financial statements.
Adequate substance means the entity has:
Adequate assets.
An adequate number of qualified employees.
Incurred adequate operating expenditures in the Free Zone. Core income-generating activities (CIGAs) must be conducted in the Free Zone.
Qualifying income includes:
Income from transactions with other Free Zone persons (excluding certain excluded activities).
Income from transactions with non-Free Zone persons related to qualifying activities.
Income from ownership or exploitation of qualifying intellectual property.
Other income, provided the de minimis requirements are met.
Qualifying activities encompass:
Manufacturing or processing of goods or materials.
Trading of qualifying commodities.
Holding of shares and other securities.
Ownership, management, and operation of ships.
Regulated reinsurance, fund management, wealth, and investment management.
Headquarter, treasury, and financing services to related parties.
Financing and leasing of aircraft.
Logistics.
Distribution of goods or materials in or from a Designated Zone.
Ancillary activities to the above.
Excluded activities include:
Transactions with natural persons (with certain exceptions).
Regulated banking, finance, leasing, and insurance activities.
Ownership or exploitation of immovable property, except for transactions with Free Zone persons in relation to commercial property located in a Free Zone.
The de minimis requirement is met if non-qualifying revenue does not exceed 5% of total revenue or AED 5 million, whichever is lower.
Exceeding the de minimis threshold results in the loss of QFZP status, and the entity becomes subject to the standard 9% corporate tax rate for the current year and the next four years.
No formal application is required. The 0% rate applies automatically if all qualifying conditions are met.
No, natural persons, unincorporated partnerships, and sole establishments are not eligible for the preferential 0% tax rate.
Yes, but income attributable to a domestic permanent establishment (PE) outside the Free Zone is subject to the standard 9% corporate tax rate.
Income from immovable property located in a Free Zone is subject to 9% tax, except for transactions with other Free Zone persons in relation to commercial property.
Yes, distribution activities must be undertaken in or from a Designated Zone to qualify for the 0% tax rate.
Entities must maintain:
Audited financial statements.
Transfer pricing documentation.
Records evidencing compliance with eligibility conditions.
Yes, but the QFZP must have adequate supervision over the outsourced activities, and the service providers should be located within the Free Zone.
The FTA administers and enforces corporate tax, including verifying compliance with QFZP conditions.
Yes, certain Free Zones offer additional incentives for specific industries, such as media, technology, and logistics.
The UAE does not impose personal income tax, making Free Zones attractive for employees. However, expatriates should consider tax obligations in their home countries.
Generally, yes. Free Zone companies are exempt from stamp duty on property transfers and capital gains tax on the sale of assets or shares, subject to specific conditions.
For more information, visit Alfa Zone.
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Tags:
Audited financial statements, Transfer pricing documentation, De minimis threshold, Taxable income exceeding AED 375,000, Non-qualifying revenue, Qualifying income, Excluded activities, Qualifying activities, Transactions with Free Zone entities, Transactions with non-Free Zone entities, Income from immovable property, Domestic Permanent Establishment (PE), Foreign Permanent Establishment, Ownership of intellectual property (IP), Qualifying Intellectual Property (QIP), Adequate economic substance, Core income-generating activities (CIGAs), Outsourcing within Free Zones, Supervision of outsourced activities, Election to standard corporate tax regime, Loss of QFZP status, Five-year disqualification period, Tax grouping restrictions, Profit repatriation, Double Taxation Agreements (DTAs), OECD Two-Pillar Solution, 15% Domestic Minimum Top-up Tax (DMTT), Global minimum tax compliance, Economic diversification initiatives, Research and development (R&D) tax incentives
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