Corporate Tax Advisory for UAE Businesses
UAE corporate tax advisory is the structured, written work of applying Federal Decree-Law No. 47 of 2022 to your specific business: choosing between Small Business Relief and standard 9% treatment, structuring free zone entities for Qualifying Free Zone Person status, documenting related-party transactions, and planning group and cross-border positions before they hit a return. asly tax provides written opinions, structuring engagements, and annual retainers, reviewed with ACME Group.
Small Business Relief
Small Business Relief lets a resident taxable person with revenue at or below AED 3 million in the current and all previous tax periods be treated as having no taxable income for that period, currently available for tax periods ending on or before 31 December 2026 under Ministerial Decision No. 73 of 2023. It is an election made inside the corporate tax return each year — not automatic — and using it forfeits the ability to carry forward tax losses or interest from the electing period.
Electing SBR simplifies the current year but blocks loss carry-forward. A loss-making business investing in growth is often better off filing a normal loss return and preserving the loss for future offset against up to 75% of taxable income.
Free Zone Companies: Qualifying for 0%
A free zone entity is taxed at 9% by default. The 0% rate applies only to a Qualifying Free Zone Person (QFZP), and only on qualifying income. QFZP status must be maintained every year — losing it in one period disqualifies the entity for that period and the following four.
- □Maintains adequate substance in the UAE free zone
- □Derives qualifying income as defined in Ministerial Decision No. 229 of 2025 (which replaced Ministerial Decision No. 265 of 2023 with retroactive effect from 1 June 2023)
- □Has not elected to be subject to the standard 9% regime
- □Complies with the arm's length principle and transfer pricing documentation
- □Prepares audited financial statements for the tax period
- □Non-qualifying revenue stays within the de minimis threshold (lower of AED 5M or 5% of total revenue)
Rules and audit panels vary by zone. See our IFZA corporate tax guide or browse all UAE free zone guides.
Mainland vs Free Zone Tax Treatment
Mainland and free zone entities operate under the same corporate tax law but face materially different compliance and planning considerations.
| Topic | Mainland | Free zone |
|---|---|---|
| Statutory rate | 9% on profits > AED 375,000 | 9% by default; 0% on qualifying income if QFZP |
| Registration required | Yes | Yes, even at 0% |
| Small Business Relief | Available if revenue ≤ AED 3M | Not available to QFZPs |
| Audited financials | Required if revenue > AED 50M | Required for all QFZPs |
| Transfer pricing | Applies to related-party transactions | Applies to related-party transactions |
| Substance requirement | General | Adequate substance in the free zone is a QFZP condition |
Transfer Pricing Requirements
Every UAE taxable person with related-party or connected-person transactions must apply the arm's length principle under Article 34 of Federal Decree-Law No. 47 of 2022. Full transfer pricing requirements include a Transfer Pricing Disclosure Form submitted with the return when thresholds are met, and a Master File and Local File maintained where the taxable person's revenue is at least AED 200 million in the tax period, or where it is part of a multinational group with consolidated revenue of at least AED 3.15 billion.
Tax Grouping and Loss Relief
A UAE tax group can be formed where a parent holds at least 95% of ownership, voting rights, and profit rights of each subsidiary, and all members are UAE resident juridical persons that are neither QFZPs nor exempt. The group files a single consolidated return and shares losses within the group. Outside a group, tax losses can be transferred between commonly-owned UAE resident entities, and unused losses can be carried forward indefinitely to offset up to 75% of future taxable income.
When You Need an Advisor vs When Filing Is Enough
Not every business needs paid advisory. Most SMEs with clean books need a competent filer, not a written opinion. Here's how we honestly triage:
Single UAE entity, clean books, revenue under AED 3M, electing Small Business Relief, no cross-border transactions, no related parties. A fixed-fee filing service will do the job.
Standard mainland LLC, profits above AED 375K, no free zone questions, no group structure, no international operations. Prepare and file — no strategic advisory needed.
Free zone entity weighing QFZP eligibility, structuring qualifying vs. non-qualifying income, or approaching the de minimis threshold.
Group with related-party transactions, cross-border payments, IP or management fees, or planning a restructuring, merger, or share transfer.
Deciding whether to elect tax grouping, transfer losses, or step into a tax period with an unusual first-period date.
Tell us the question. We'll tell you honestly whether it needs an advisor or just a good filer.