Introduction to UAE Corporate Tax

In December 2022, the Ministry of Finance of the United Arab Emirates (“UAE”) released Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses (“CT Law”), introducing a federal corporate tax regime for the first time in the country. The regime is designed to enhance the UAE’s position as a leading global business hub while aligning with international tax standards, including the OECD’s Base Erosion and Profit Shifting (“BEPS”) framework.

The Corporate Tax Law sets a standard corporate tax rate of 9% on taxable income exceeding AED 375,000, with income below this threshold taxed at 0% to support small businesses and start-ups. Specific exemptions apply to certain entities such as government bodies, extractive industries, and qualifying investment funds. Free Zone entities may also benefit from a 0% rate on qualifying income, provided they meet the conditions laid out in the law and accompanying decisions.

The introduction of the Corporate Tax Law was further clarified by a series of Cabinet and Ministerial Decisions throughout 2023 and 2024, covering key areas such as qualifying Free Zone income, business restructuring reliefs, participation exemptions, and Small Business Relief (SBR). Guidance has also been issued to help businesses navigate transitional rules, reporting requirements, and compliance obligations. 

The UAE Corporate Tax Law applies to financial years beginning on or after June 1, 2023. As a result, many businesses are now in their first corporate tax reporting period and are undertaking corporate tax impact assessments, compliance planning, and return preparation. With the reporting cycle now active, it is imperative for businesses to implement the appropriate systems and controls to ensure compliance with the UAE’s corporate tax framework.

How can we assist you?

  • Review of ownership structure and financials
  • Analyse group structure (holding, free zone, offshore, mainland) for tax status and implications.
  • Conduct an analysis of income types and expenses
  • Assess potential exempt sources of income (dividends, capital gains, participation exemption).
  • Identify disallowable expenses, restrictions on deductions, and interest limitation rules. 
  • Review unrealised gains/losses and intra-group transactions for deductibility.
  • Assess the impact of Free Zone entity benefits and potential CT exposures.
  • Provide high-level tax structuring and planning opportunities
  • Explore eligibility for group relief or tax grouping.
  • Evaluate future challenges in taxable income determination.
  • Provide practical recommendations to mitigate risks and optimise CT position.
  • Explain FTA requirements, timelines, and documentation needed for registration.
  • Assist in compiling the required details
  • Liaison with the FTA Portal by completing the online registration process on the FTA portal.
  • Track the application status with the FTA.
  • Assist in addressing any system queries or clarifications during the application.
  • Providing advise on updating registration details in case of structural/business changes.
  • FTA Notification & Procedure Management
  • Obtain confirmation from the FTA that there are no outstanding Corporate Tax obligations post deregistration.
  • Final Tax Return Filing for the liquidation period
  • Support management with timely follow-up to secure approval of the deregistration application.
  • Post-Deregistration Support
  • Preparation of Corporate Tax Computation based on the financial statements.
  • Detailed review of income & expense breakdowns.
  • Highlight potential exempt streams and restricted deductions.
  • Analyse temporary differences and positions giving rise to deferred tax.
  • Align with IAS 12 requirements and UAE CT law interpretations.
  • Consider Management’s adopted positions (e.g., unrealised gains/losses, transitional rules).
  • Ensure consistency with FTA guidance and Cabinet/Ministerial Decisions.
  • Assess the information shared by management and highlight findings before submission.
  • Ensure disclosures and supporting documentation are consistent with UAE CT requirements.
  • Prepare the tax computation based on latest available financial statements.
  • Focus on specific CT complexities (e.g., FTA clarifications, industry-specific rules, transitional provisions).
  • Provide insights to mitigate potential risks during return preparation.
  • Assist with uploading and filing the CT return on the FTA’s EmaraTax portal.
  • Review existing frameworks, internal resources, processes, and material tax risks within the Group
  • Recommend improvements to align with key tax performance metrics and best practices, supporting readiness for UAE Corporate Tax implementation.
  • Design of Tax Decision-Making Matrix that covers; Internal controls for tax risk management, Group tax policy, Chain of tax reviews and approval mechanisms, Tax procedures and executive reporting and Tax awareness and reporting)
  • Tailored Written Advice on potential UAE Corporate Tax implications.
  • Interpretation of Double Tax Treaties, offering written guidance on the application of specific treaty clauses signed by the UAE.
  • Corporate Tax Awareness Training Sessions, designed to enhance understanding within the permitted time threshold.
  • Assistance with FTA Clarifications 
  • Ad-Hoc Corporate Tax Support for any additional requirements as they arise.

When to reach out

At the planning stage

  • When you need clarity on how UAE Corporate Tax Impacts your Compay’s income, expenses,  or to avail the Free Zone benefits.
  • If you want to identify tax risks, opportunities, and structuring options before year-end.

Before financial year close

  • To assess potential disallowed expenses, deferred tax positions, and transitional rule implications.
  • For provisional tax computations to support management reporting and decision-making.

Ahead of registration deadlines or ungergoing liquidation process

  • When your entity becomes liable for UAE CT and needs to complete registration with the FTA
  • When the entity is closing down or undergoing liquidation and needs to deregister from UAE Corporate Tax.
  • To ensure accuracy and compliance in the EmaraTax registration and de-registration process.

At corporate tax return preparation time

  • When compiling CT return data, reconciliations, and supporting schedules for submission.
  • If you require assistance in reviewing computations, addressing complex areas, or filing through the EmaraTax portal.

During business or structural changes

  • If your group is restructuring, entering new transactions, or expanding cross-border operations.
  • To assess CT implications on related party transactions, transfer pricing, and group relief opportunities.