Qualifying Free Zone Person analysis, substance testing, income segregation. The 0% CT rate isn't automatic — it has to be earned and evidenced.
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 →Employees, premises and operating expenditure in the Free Zone — proportionate to the income generated. Testing needs to happen before year-end, not after.
The list is narrower than most Free Zone marketing suggests. We map each revenue stream to the FTA list and flag exposures.
Non-qualifying revenue must stay below the lower of AED 5m or 5% of total revenue. Breach it and QFZP status is lost for the year.
Arm’s-length pricing rules apply even to QFZP income streams. Documentation is non-optional above threshold.
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