tax · 10 min
UAE corporate tax and free zones: who actually pays 0%
Qualifying income, substance requirements and the registration obligation that applies even at a zero rate.
Updated
The phrase "tax-free Dubai" was accurate until 2023. It is not accurate now, and a surprising amount of advice online has not caught up.
What changed
The UAE introduced a federal corporate tax regime effective for financial years starting on or after 1 June 2023. Mainland companies pay 0% on taxable profits up to AED 375,000 and 9% above that. That is still low by international standards, but it is not zero, and it comes with a full compliance apparatus: registration, record-keeping, annual returns and deadlines with penalties attached.
How free zones fit
Free zone companies can still access a 0% rate, but it is conditional rather than automatic. The company must be a Qualifying Free Zone Person, which requires maintaining adequate substance in the UAE, deriving qualifying income, complying with transfer pricing rules, and not having elected to be taxed at the standard rate.
Two phrases carry the weight. "Adequate substance" means real activity in the UAE — people, premises, expenditure proportionate to what the business claims to do. A flexi-desk with nobody at it is not substance. "Qualifying income" is a defined category; income falling outside it is taxed at 9%, and in some cases non-qualifying revenue above a de minimis threshold can disqualify the company entirely for that period and the following ones.
The obligation nobody mentions
Registration for corporate tax is mandatory for every UAE company, including one that expects to pay nothing. The return must be filed even where the result is zero. Late registration and late filing both carry administrative penalties.
This matters commercially because it changes the annual cost of ownership. A company that used to cost a licence renewal now costs a licence renewal plus bookkeeping plus a tax return. Any cost comparison built on pre-2023 figures understates the real number.
What this means for your decision
For a small service business the practical effect is often modest — profits under the threshold, or qualifying income properly structured, still land at or near 0%. For a business with UAE-mainland customers, or with income types outside the qualifying definition, 9% is the realistic planning assumption and should be modelled rather than hoped away.
The larger point is that the UAE now has a tax system, with filings, deadlines and auditors. Treat it as a jurisdiction with low rates and real compliance, not as a place where tax does not exist. Anyone still selling it as the latter is either out of date or not telling you everything.
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