Compare Mainland vs Free Zone (QFZP) vs Multinational (Pillar Two DMTT) scenarios. Includes Small Business Relief and the AED 375k threshold.
The Ministry's clarification narrows the definition of "qualifying activities" and reintroduces substance thresholds. Here's the practical read-through for holding structures.
Read the briefing →0% up to AED 375k. 9% above. QFZP 0% on qualifying income if ≥95% qualifying share and substance test met. Small Business Relief: 0% for revenue ≤ AED 3m (periods ending ≤ 31 Dec 2026). Pillar Two 15% top-up for MNEs above ~AED 3bn global revenue. Not tax advice — book a CT review.
Full 9% CT scope above AED 375k. Small Business Relief available for revenue ≤ AED 3m (periods ending on or before 31 Dec 2026).
0% on qualifying income if qualifying share ≥ 95% and substance test met. 9% on non-qualifying income. De minimis: lower of 5% or AED 5m.
Free Zone entity that has failed QFZP conditions — 9% full-scope Corporate Tax applies, same as Mainland.
MNEs with consolidated global revenue above ~AED 3.0bn (EUR 750m). UAE Domestic Minimum Top-up Tax brings the effective rate to 15%. Effective from FY starting 1 Jan 2025.
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