On the 28th of August 2025, the Ministry of Finance released Ministerial Decision No. 229 of 2025, updating the rules for Qualifying free zone person UAE corporate tax under Federal Decree-Law 47 of 2022. This decision replaces MD 265/2023, with most provisions intact, but key refinements introduced.
Please check our previous article where we discussed the New Corporate Tax Guide for Free Zone Persons.
What’s New for Qualifying free zone person UAE Corporate Tax?
- Commodities Expanded – Now includes industrial chemicals and environmental commodities (carbon credits, renewable energy certificates), with a Quoted Price requirement.
- Commodity Trading Broadened – Covers structured commodity financing (prepayment, factoring, countertrade). Excludes businesses with ≥51% revenue from distribution, logistics, or warehousing.
- Treasury & Financing – Can now be conducted for own account, not only for related parties.
- Distribution Recipients – Public benefit entities are now included.
- Regulatory Updates – Insurance under FDL 48/2023, audited accounts per MD 84/2025.
- Ministerial Discretion – Authority to name new competent authorities and recognized exchanges.
Seeking direction or exploring opportunities?
Contact us by using the form below.
What Stays the Same for Qualifying free zone person UAE Corporate Tax?
- De minimis rule (≤5% or AED 5M non-qualifying revenue).
- Ancillary activity definition.
- Qualifying IP rules and 30% uplift on qualifying expenditures.
- Cessation rules for failing conditions.
- Effective date remains 1 June 2023.
Why It Matters for Qualifying free zone person UAE Corporate Tax?
The updates reflect the UAE’s drive toward sustainable growth and financial innovation, widening opportunities for companies seeking to qualify under the qualifying free zone person UAE framework.
If you are interested in investing in the UAE, you can read our guide Doing Business in the UAE.