UAE QFZP Compliance How to Maintain Your 0% Corporate Tax Status

A Qualifying Free Zone Person (QFZP) is a UAE free zone entity that maintains 0% corporate tax, one of the key UAE free zone tax benefits under the new regime by meeting specific regulatory conditions. Introduced under UAE Federal Decree-Law No. 47/2022, the QFZP regime allows eligible free zone companies to benefit from complete corporate tax exemption, provided they satisfy stringent compliance requirements set by the Federal Tax Authority.

The QFZP status represents a continuation of the UAE's traditional free zone tax benefits under the new corporate tax framework. However, unlike the previous system, QFZP status is not automatic and requires active compliance monitoring. Companies must demonstrate ongoing adherence to qualifying conditions or face immediate corporate tax liability at the standard 9% rate.

📌 New to UAE Free Zones?

• Understand the tax implications: Free Zone 0% vs Mainland 9% Tax Guide
• Compare business structures: Dubai Free Zone vs Mainland Company

The Federal Tax Authority has established five mandatory conditions for QFZP status. All conditions must be satisfied simultaneously throughout the entire tax period. Failing any single condition results in immediate loss of QFZP status and triggers corporate tax liability for the full tax year.

Condition 1: Free Zone License Requirement

The entity must hold a valid free zone license issued by a designated UAE free zone authority. This license must remain active throughout the tax period, and any suspension or revocation immediately disqualifies QFZP status. The license must authorize the specific business activities being conducted.

Condition 2: Adequate Substance Requirements

Companies must maintain adequate substance within the UAE free zone, including physical office space, qualified employees, and core income-generating activities conducted locally. The Federal Tax Authority evaluates substance based on the nature and scale of business operations, with higher-revenue entities facing stricter substance requirements.

Condition 3: Qualifying Income Threshold

At least 95% of total income must constitute qualifying income as defined by the Corporate Tax Law. Non-qualifying income cannot exceed 5% of total income (the de minimis rule). This calculation includes all revenue streams, investment income, and gains from asset disposals.

Condition 4: No Mainland UAE Business

The entity cannot conduct business with UAE mainland entities or UAE residents, except for transactions specifically permitted under the Corporate Tax Law. This restriction includes sales, services, and investment activities targeting the UAE domestic market.

Condition 5: Regulatory Compliance

Full compliance with all applicable UAE laws, regulations, and free zone authority requirements is mandatory. This includes timely filing of all required returns, maintaining proper accounting records, and submitting to mandatory audit requirements.

→ Need a visa to establish substance in UAE? See our UAE Visa & Work Permit Guide

The distinction between qualifying and non-qualifying income is crucial for maintaining QFZP status. The Federal Tax Authority applies the de minimis rule, allowing up to 5% of total income to be non-qualifying without losing QFZP status. However, exceeding this threshold by even 0.1% results in complete loss of the 0% tax rate.

Qualifying income includes revenue from goods or services provided to non-UAE residents, income from free zone business activities conducted outside the UAE, and specific investment income as defined in the Corporate Tax Law. Non-qualifying income primarily consists of UAE mainland business activities and domestic market transactions.

Example: A UAE free zone company earns AED 10 million total revenue. Maximum allowed non-qualifying income = 5% = AED 500,000. If UAE mainland sales reach AED 510,000, QFZP status is lost for the entire year.

📊 Track your income classification monthly with a simple spreadsheet.

Adequate substance represents one of the most scrutinized QFZP requirements. The Federal Tax Authority evaluates substance based on the principle that tax benefits should align with genuine economic activity. Companies must demonstrate that core income-generating activities occur within the UAE free zone through physical presence, qualified personnel, and operational infrastructure.

Substance requirements scale with business complexity and revenue levels. Higher-revenue entities face stricter scrutiny, with the FTA expecting substantial local operations, senior management presence, and significant decision-making authority located within the free zone. The authority conducts regular substance reviews and may request detailed documentation of local activities.

• Physical Office Space: Adequate premises within the designated free zone, proportional to business operations
• Qualified Employees: Sufficient full-time staff with appropriate qualifications for core business functions
• Local Decision Making: Board meetings, strategic decisions, and management oversight conducted in the UAE
• Operational Infrastructure: IT systems, equipment, and resources necessary for business operations located locally

All QFZPs must undergo mandatory annual audits regardless of revenue size or business complexity. This requirement differs significantly from UAE mainland corporate tax rules, where audit thresholds apply. The Federal Tax Authority mandates that QFZP audits be conducted by UAE-licensed auditors familiar with corporate tax compliance requirements.

The audit must specifically address QFZP compliance, including verification of the five qualifying conditions, income classification accuracy, and substance requirement fulfillment. Auditors must provide detailed reports confirming ongoing QFZP eligibility, and any qualification or adverse finding may trigger FTA investigation.

QFZP status failures occur more frequently than many companies anticipate. The Federal Tax Authority has identified several common scenarios where entities lose their qualifying status, often due to operational changes or compliance oversights. Understanding these failure patterns helps companies implement preventive measures and maintain their 0% corporate tax rate.

The penalty for losing QFZP status is severe: immediate liability for 9% corporate tax on all income, with a minimum 5-year period before re-qualification is possible. This penalty applies retroactively to the beginning of the tax year in which the failure occurred, regardless of how late in the year the qualifying conditions were breached.

• Exceeding Non-Qualifying Income Threshold: Most common failure, UAE mainland sales pushing non-qualifying income above 5% limit
• Inadequate Substance Documentation: Inability to demonstrate sufficient local operations during FTA substance reviews
• License Compliance Issues: Free zone license suspension, renewal delays, or unauthorized business activities
• Mainland Business Expansion: Inadvertently conducting prohibited UAE domestic market activities
• Audit Non-Compliance: Failing to complete mandatory annual audits or receiving qualified audit opinions

Maintaining QFZP status involves significant compliance costs that companies must budget for annually. These costs represent the price of accessing 0% corporate tax and should be evaluated against the tax savings achieved. The Federal Tax Authority's strict compliance requirements have created a robust compliance services market with established fee structures.

Compliance costs vary based on business complexity, revenue levels, and existing internal capabilities. Companies with sophisticated operations, multiple revenue streams, or complex substance arrangements face higher compliance costs due to increased documentation and audit requirements.

All amounts in AED. Prices shown are indicative only, based on market research as of January 2026, and may vary by provider, free zone authority, and business complexity.

Mandatory Audit Costs

• Annual audit fees: AED15000 - AED50000
• Audit preparation support: AED5000 - AED15000 (optional)
• Specialized QFZP audit procedures: AED3000 - AED10000

Legal & Tax Compliance

• Corporate tax return preparation: AED8000 - AED25000
• QFZP compliance monitoring: AED12000 - AED30000 (optional)
• Legal compliance review: AED5000 - AED20000 (optional)

Substance Requirements

• Office space rental: AED20000 - AED100000
• Employee costs: AED60000 - AED300000
• Operational infrastructure: AED10000 - AED50000

💰 First Year Total: AED138000 - AED600000

📅 Annual Ongoing: AED138000 - AED600000

⚠️ Factor in potential FTA investigation costs, compliance remediation, and professional fees for complex rulings.

Already operating as QFZP? This section helps you evaluate whether to continue or consider alternatives.

The decision to pursue or maintain QFZP status requires careful cost-benefit analysis considering compliance costs, operational requirements, and business objectives. While 0% corporate tax provides significant savings, the associated compliance burden and operational restrictions may not suit all business models.

Companies should evaluate QFZP suitability based on their export focus, revenue levels, operational flexibility requirements, and long-term business strategy. The five-year penalty period for status loss makes this a high-stakes decision requiring thorough analysis and ongoing commitment to compliance.

→ Considering restructuring? Compare your options in our UAE Company Formation Guide

These compliance failures have cost companies their QFZP status and triggered years of corporate tax liability:

Treating QFZP status as automatic for free zone entities

❌ Consequence: Failure to monitor qualifying conditions leads to inadvertent status loss and retroactive tax liability

✅ How to avoid: Implement formal QFZP compliance procedures from day one with regular condition monitoring and documentation

Underestimating substance requirements for smaller businesses

❌ Consequence: FTA substance reviews find inadequate local operations, resulting in QFZP status revocation

✅ How to avoid: Maintain genuine local operations proportional to business size with proper documentation of all local activities

Expanding UAE mainland business without income impact analysis

❌ Consequence: Non-qualifying income exceeds 5% threshold, triggering immediate QFZP status loss

✅ How to avoid: Model income impact before pursuing any UAE domestic business opportunities and maintain monthly income classification tracking

Delaying mandatory audit completion until filing deadline

❌ Consequence: Rushed audits miss compliance issues and may result in qualified opinions affecting QFZP status

✅ How to avoid: Begin audit process 6 months before filing deadline with experienced QFZP-specialized auditors

Assuming corporate tax rules mirror other UAE tax regimes

❌ Consequence: Misunderstanding QFZP requirements leads to non-compliance and unexpected tax exposure

✅ How to avoid: Engage specialists familiar with UAE corporate tax law rather than relying on general UAE tax knowledge

Ignoring the Registration Deadline

❌ Consequence: Missing the 3-month registration deadline permanently disqualifies companies from QFZP status with no appeals process

✅ How to avoid: Register for corporate tax immediately after incorporation, don't wait for the deadline

Poor Income Classification

❌ Consequence: Misclassifying income as qualifying when it's not can breach the de minimis rule and eliminate exemptions

✅ How to avoid: Carefully analyze all revenue streams and obtain professional advice on income classification

Information compiled from official Federal Tax Authority publications, UAE Corporate Tax Law analysis, and practical compliance experience from 2023-2025 implementation period.

• Federal Tax Authority - Corporate Tax: https://tax.gov.ae/en/taxes/corporate.tax.aspx (accessed 2026-01-23)
• QFZP Ministerial Decision: https://tax.gov.ae/en/taxes/corporate.tax/corporate.tax.topics/qualifying.free.zone.person.aspx (accessed 2026-01-23)
• UAE Ministry of Finance: https://www.mof.gov.ae (accessed 2026-01-23)
• PwC UAE Tax Summary: https://taxsummaries.pwc.com/united-arab-emirates/corporate/tax-credits-and-incentives (accessed 2026-01-23)

Information accurate as of January 2026. QFZP requirements may change, verify current conditions with the Federal Tax Authority and qualified tax advisors.

For ongoing accounting and Corporate Tax compliance support, see our UAE Accounting & Bookkeeping Guide.