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Corporate tax planning has become an essential component of doing business in the United Arab Emirates. With the introduction of the UAE Corporate Tax Law and the continuing evolution of tax regulations under the Federal Tax Authority (FTA), businesses must adapt their financial and operational strategies to remain compliant with tax laws while optimising their overall tax position and achieving maximum tax efficiency.
This comprehensive guide explains the principles, requirements, and strategies for corporate tax planning in the UAE. It integrates the practical implications for all entities, ensuring a complete and authoritative resource suitable for professionals, CFOs, and decision-makers looking for tax savings and reduction of their tax burden.
The United Arab Emirates (UAE) has historically been recognised for its business-friendly environment. However, with global regulatory shifts and economic diversification strategies, the UAE introduced its first-ever federal corporate tax regime through Federal Decree-Law No. 47 of 2022. This new corporate tax applies to all entities conducting business in the UAE, whether in the mainland or in free zones, fundamentally reshaping the tax landscape.
• Standard Corporate Tax Rate: 9%
• Tax Exemption Threshold: Income below AED 375,000 taxed at 0%
• Effective Date: June 2023 for certain financial years; majority apply from January 2024
• Scope: Applies to both UAE resident businesses and non-residents with a UAE nexus
• Regulatory Authority: Federal Tax Authority (FTA)
• Compliance Pillars: Registration, filing, documentation, transfer pricing, financial reporting
This law fundamentally reshapes how companies plan their operations, allocate resources, structure entities, and approach financial management.
Corporate tax planning involves evaluating a company’s business structure, revenue flows, expenses, and operating jurisdictions to legally minimize their tax liability while meeting all tax obligations.
In the UAE context, effective corporate tax planning and management is not merely about reducing corporate tax liabilities. Planning helps businesses ensure:
• Full compliance with the Corporate Tax Law.
• Strategic use of tax benefit and relief mechanisms.
• Efficient structuring for mainland and free zone operations.
• A significantly reduced overall tax burden.
• Long-term sustainability aligned with regulatory expectations.
The primary goal is tax optimization—a core strategy for improving profitability and preparing for audits. Seeking the advice of a tax advisor or tax professional is often the first step.
Corporate tax planning is a crucial element of financial management in the UAE's evolving fiscal landscape. By utilizing specialized corporate tax advisory and tax advisory services, businesses can strategically navigate the complexities of corporate tax in UAE. These advisory services provide tailored strategies in the UAE for optimizing structures, ensuring compliance, and maximizing available tax benefits. The resulting benefits of these professional services in UAE (including dedicated services in Dubai) are essential for successful planning for corporate sustainability and long-term financial health.
The UAE Corporate Tax Law outlines how taxable income is calculated, what deductions are allowed, and how businesses must account for related party transactions, financial records, and group structures.
Free zone companies represent a significant share of the UAE’s commercial activity. Under the Corporate Tax Law, the concept of a Qualifying Free Zone Person (QFZP) plays a major role in tax planning.
Qualifying Free Zone Person (QFZP)
To maintain QFZP status and benefit from 0% tax on qualifying income, an entity must meet:
• Substance Requirements: Adequate staff, office, and operations in the free zone
• Qualifying Income Criteria
• Audited Financial Statements
• De-minimis Thresholds for non-qualifying income
Consequences of Non-Compliance
Failure to meet QFZP conditions results in:
• Loss of status
• Entire income taxed at 9%
• Ineligibility for QFZP benefits for the next five tax periods
Qualifying Income Categories
Qualifying income generally includes:
• Transactions with other free zone persons
• Income from certain allowed activities such as:
• Manufacturing
• Holding shares or securities
• Regulated financial services
• Distribution within designated zones
Corporate tax planning for free zone companies must therefore focus on:
• Ensuring operational substance
• Segregating qualifying vs non-qualifying income
• Maintaining compliant documentation
Taxable Person
A taxable person includes:
• UAE-resident legal entities
• Natural persons conducting business activities
• Free zone companies
• Non-residents with a permanent establishment or “nexus” in the UAE
This broad definition means most business activities fall under the tax regime.
The participation exemption is a vital corporate tax planning mechanism applicable to:
• Dividends
• Capital gains
• Foreign exchange gains or losses
• Gains or losses from share disposals
To qualify, the entity must hold:
• Minimum 5% ownership interest in the foreign company
• Rights to at least 5% of profits and liquidation proceeds
• Participation in a jurisdiction where the foreign company is taxed at ≥9%
This allows UAE companies to structure their investments efficiently, reducing tax exposure while enabling expansion into global markets.
Corporate tax planning often involves analysing whether forming a Tax Group will provide strategic benefits.
The parent entity must own:
• 95% of share capital
• 95% of voting rights
• 95% of profits and net assets
• Single tax return for the entire group
• Intra-group transactions ignored for tax purposes
• Streamlined reporting and compliance
This significantly improves tax administration for entities with complex operating structures.
Apart from tax grouping, the law recognises Qualifying Groups, allowing:
• Transfer of assets or liabilities at “no gain, no loss”
• Transfer of tax losses between group companies
Ownership requirement: one entity must hold ≥75% of the other, or a third party must hold ≥75% of both.
This is particularly useful when planning restructurings, mergers, or expansions.
Small entities may reduce tax compliance burdens through Small Business Relief, applicable until 31 December 2026.
• Annual revenue ≤ AED 3 million
• Effectively results in zero taxable income
• Qualifying Free Zone Persons
• MNE groups falling under Pillar Two
• Entities exceeding the revenue threshold
Tax planning for small businesses involves evaluating whether to use this relief or opt out for long-term tax advantages.
Certain categories of entities are exempt from corporate tax, including:
• Government entities
• Extractive and non-extractive natural resource businesses
• Qualifying public benefit entities
• Pension funds and investment funds
• Select entities under ministerial decision
Understanding exempt status is critical for structuring investment vehicles, holding companies, or charitable institutions.
Global tax changes under OECD’s BEPS 2.0 introduce Pillar Two, requiring multinational groups with revenue ≥ EUR 750 million to meet a global minimum tax rate.
Implications for corporate tax planning:
• MNEs must assess effective tax rates across jurisdictions
• UAE structures may require realignment
• Small business relief is not available
• Transfer pricing compliance becomes critical
MNEs must integrate UAE regulations with global tax frameworks to ensure streamlined reporting and adherence.
During mergers, acquisitions, or business transfers, UAE law allows no-gain/no-loss treatment provided continuity conditions are met.
Business restructuring relief is vital for:
• Corporate reorganisations
• Spin-offs
• Asset transfers
• Consolidating group entities
Corporate tax planning must ensure that all conditions are met and future transactions remain compliant.
Transfer pricing governs transactions between related parties and applies to:
• Goods
• Services
• Financing
• Royalties
• Management fees
The UAE follows OECD-aligned transfer pricing rules, requiring:
• Arm’s length pricing
• Comprehensive documentation
• Maintenance of a Master File and Local File, depending on thresholds
Transfer Pricing compliance is central to tax planning because improper documentation can result in:
• Tax adjustments
• Penalties
• Loss of reliefs
• Increased FTA scrutiny
Below are key components of a robust tax planning framework:
1. Entity Structuring
• Choosing between mainland, free zone, or hybrid setups
• Assessing eligibility for QFZP
• Aligning structure with business objectives
2. Income Segregation
• Categorising qualifying vs non-qualifying income
• Evaluating sources of foreign income
• Understanding participation exemption benefits
3. Cost Allocation
• Ensuring deductibility of business expenses
• Avoiding prohibited deductions
• Applying correct allocation methods for group entities
4. Transfer Pricing Policies
• Drafting compliant TP policy
• Maintaining arm’s length pricing
• Documenting related-party transactions
5. Tax Group/Qualifying Group Considerations
• Identifying benefits of consolidated reporting
• Transferring losses strategically
• Restructuring assets within legal allowances
6. Financial Reporting
• Ensuring audited financial statements
• Maintaining proper books for seven years
• Reconciling accounting profit with taxable income
7.Compliance Monitoring
• Meeting FTA registration deadlines
• Filing annual returns
• Preparing for potential audits
The FTA governs:
• Corporate tax registration
• Return filing and payments
• Review and audits
• Issuance of executive regulations
• Guidance and clarifications
A well-designed tax planning framework ensures complete alignment with FTA expectations and avoids penalties or non-compliance risks.
At Young & Right, we specialise in corporate tax planning in UAE and corporate tax planning in Dubai, helping businesses navigate the new corporate tax system with confidence. Our goal is simple: to design practical corporate tax strategies that minimize tax, support growth, and keep you fully compliant with tax in the UAE.
Our team of experienced corporate tax consultants in Dubai starts by understanding your business model, group structure, and relevant tax period. We then develop strategic tax roadmaps tailored to your sector—covering business tax planning, corporate income tax, international tax exposure, and any tax implications of cross-border or related-party transactions. This kind of effective tax planning and corporate tax management helps you make informed decisions before you commit to major contracts or restructuring.
We also assist you in identifying legitimate tax deduction opportunities and available tax credit mechanisms under corporate tax in the UAE. Our structured tax planning helps you legally reduce your tax burden and optimize your tax position while staying aligned with the corporate tax rate of 9 for businesses subject to corporate tax. Throughout the year, we support you with accurate tax filing, documentation, and compliance with tax rules so there are no surprises from the authorities.
Corporate tax planning in the UAE is a mandatory, proactive strategic function. It ensures your business remains compliant with tax laws while leveraging every available provision in the Corporate Tax Law for tax optimization. By strategically using the 0% threshold, Qualified Free Zone status, Group Relief, and Participation Exemption, businesses can significantly reduce your tax liabilities and secure their financial future in the UAE’s tax dynamic environment.
Don't leave your new tax obligations to chance. Seek out expert corporate tax planning services to tailor a strategy to your business needs, minimize your tax bill, and maximize your tax benefit opportunities.
Stay Ahead of the Curve and Maximize Your Tax Efficiency with Tailored Strategies for the UAE Corporate Tax Law.
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