It's been just under two years since the UAE rolled out federal corporate tax at 9%, and the questions in our inbox haven't slowed down. Most of them sound a lot like this: "Are we actually paying tax this year, and if so, how much?"
The honest answer is: it depends. The rules are simpler than most jurisdictions, but they have edges, qualifying free zone income, small business relief, group elections, the new transfer pricing requirements, and missing one of those edges is what trips up most founders.
This guide is the version we wish we had when CT first came into force. We'll cover every category of business, the thresholds that matter, and the four mistakes we see again and again in voluntary disclosures.
What you'll learn
→ Who actually pays UAE corporate tax → Small business relief, in plain English → The free zone "qualifying income" rule → Transfer pricing for groups → When and how to file → The four most expensive mistakesWho actually pays UAE corporate tax?
Almost every UAE-resident business, mainland LLCs, free zone companies, branches of foreign companies, falls within scope. There are a few notable exceptions: government entities, qualifying public benefit entities, certain investment funds and pension funds, and natural persons who don't carry on a "business activity" above the AED 1M threshold.
For everyone else, the regime works in two brackets:
- 0% on taxable income up to AED 375,000 per year.
- 9% on taxable income above AED 375,000.
That AED 375K threshold applies to every single legal entity individually, even if you have multiple licences under one beneficial owner. (We'll come back to grouping later.)
"The biggest misconception we see is founders assuming corporate tax replaces their free zone benefits. It doesn't, but only if you stay inside the qualifying income rules."
Small business relief, for revenue under AED 3M
If your revenue (not profit, revenue) for the financial year is below AED 3,000,000, you can elect into Small Business Relief (SBR). SBR effectively treats you as having zero taxable income, regardless of your actual profit. You still need to file, but the bottom-line tax payable is zero.
This relief was designed to ease the burden on early-stage and lifestyle businesses, and it's available until the end of 2026 (the FTA may extend, but assume it won't). Three caveats:
- You can't be a Qualifying Free Zone Person and claim SBR. You pick one.
- It's an election, you have to actively claim it on your return; it isn't automatic.
- It applies entity-by-entity, so a holding structure can have one entity on SBR and another on standard 9%.
Quick example
Let's say you're a two-person consultancy in IFZA. You bill AED 1.8M a year, with about AED 1.3M in profit. Without SBR, you'd owe roughly (1,300,000 − 375,000) × 9% = 83,250 AED. With SBR, you owe nothing. The election takes 90 seconds in your Acowntant return.
The free zone "qualifying income" rule
If you operate in a designated free zone (DMCC, JAFZA, DIFC, ADGM, IFZA, RAKEZ and 25 others) you can still pay 0%, as a Qualifying Free Zone Person (QFZP), provided your income is "qualifying."
What counts as qualifying:
- Income from transactions with other free zone persons (the "B2FZ" stream).
- Income from a list of qualifying activities, manufacturing, holding shares, fund management, ship leasing, treasury services, certain logistics, and more.
- Limited income from outside the UAE, if not attributable to a UAE permanent establishment.
What does not count:
- Income from UAE mainland customers (this is the one that catches most consultancies).
- Income from natural persons (B2C revenue, with narrow exceptions).
- Income from "excluded activities", banking, insurance, real estate other than commercial leasing.
The kicker: there's a "de minimis" allowance, non-qualifying income up to AED 5M or 5% of total revenue (whichever is lower) is allowed. Cross that line, even by AED 1, and you lose QFZP status for that year and the next four. Yes, four years.
// QFZP test (simplified)
qualifying_income = freezone_b2b + qualifying_activity + foreign_income;
non_qualifying_income = mainland_b2b + b2c + excluded;
is_qualifying = non_qualifying_income <= min(0.05 × total_revenue, 5_000_000);
tax_rate = is_qualifying ? 0% : 9%;
Transfer pricing for groups
If you have related-party transactions, say your DMCC entity invoices your offshore holding company, or your operating company pays a "management fee" to your free zone parent, you now need to document those at arm's length.
The thresholds:
- Master File & Local File required if either: revenue > AED 200M, or you're part of an MNE with global revenue > AED 3.15B.
- Disclosure form required for all entities with related-party transactions > AED 500K aggregate.
- Documentation for the basis (cost-plus, comparable uncontrolled price, TNMM, etc.) is mandatory regardless of size if such transactions exist.
Most SMEs we work with use a simple cost-plus or service-fee model and produce the disclosure form within their year-end pack. Acowntant generates this automatically from your inter-company journals.
When and how to file
Your CT return is due 9 months after your financial year-end. So if you close December 31, your CT-101 return is due by September 30 of the following year. Tax payable on the same date, you can't split, can't defer.
You also need to file even if you owe nothingincluding if you've claimed SBR or you're a QFZP. Skipping the return triggers an automatic AED 500 fine that grows monthly. Don't.
The four mistakes we see most often
1. Forgetting that holding companies pay too
If you have a holding LLC in DMCC and operating subsidiaries everywhere, the holding company is a separate taxpayer. Even if it earns nothing but dividends from its subs, it has filing obligations and might owe tax on management fees it charges out.
2. Mixing personal and business expenses
Once your books are reviewed by the FTA, every line that "looks personal" gets disallowed. Restaurant bills with no business attendee logged. Family travel charged through. Domestic phone bills. We've seen disallowances of AED 200K+ on companies with sloppy records, so log everything.
3. Misclassifying mainland sales as B2FZ
Selling to a free zone branch of a mainland company is mainland income, not free zone B2FZ income. The FTA looks through to the customer's licence type. Get this wrong and your QFZP status goes.
4. Not electing into the right group structure
If you have multiple UAE entities under common ownership, you may benefit from forming a Tax Group (CT-G). The group files one consolidated return and intercompany transactions disappear for tax. The election has to be made before year-end, there's no retroactive grouping.
The takeaway
UAE corporate tax is, by international standards, still one of the simplest regimes around. But "simple" doesn't mean "automatic." For most founders, the right move is:
- Confirm your entity type and the rule that applies (SBR, QFZP, or standard 9%).
- Tighten your bookkeeping now so year-end isn't a forensic exercise.
- If you have intercompany flows, document them this quarter.
- File your return on time, even if you owe zero.
If any of that sounds like work you don't want to do yourself, we built Acowntant precisely for this. Open a free account, connect your bank, and our AI will draft your full year-end pack for an accountant to review. Or hire one of ours from the marketplace, most file UAE corporate tax in under an hour.
This guide is general information, not tax advice. Specific situations (especially groups, M&A, and cross-border flows) need professional review. Talk to your accountant, or ours.