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Regulatory Update
Tax June 2026 5 min read

MoF clarifies QFZP qualifying income: what free zone companies need to check

A 2025 Ministry of Finance clarification sharpens the line between qualifying and non-qualifying income for a Qualifying Free Zone Person. Services billed to UAE mainland entities are confirmed non-qualifying, and dividend treatment is clearer. If your 0% rate matters, this detail decides it.

Manish Kumar Pandey
Manish Kumar Pandey
Founder, DM Consultancy · UAE Business Advisory
What changed

The 0% rate was never a free zone postcode. The Ministry has now said so plainly.

A Qualifying Free Zone Person pays 0% corporate tax on qualifying income and 9% on everything else, so the whole benefit lives in two words: qualifying income. The 2025 clarification does not rewrite the law. It reads the existing Cabinet and Ministerial Decisions back where companies had resolved doubt in their favour, and closes two gaps: income billed to a UAE mainland entity is non-qualifying, and dividend income is categorised more sharply. If you assumed you were inside the regime, check now.

What is actually at stake

A breach does not tax the mainland slice. It taxes everything.

The regime tolerates a limited amount of non-qualifying revenue, the de minimis allowance, before a company drops out of 0% entirely. Cross that line and the standard rate hits all your taxable income for the period, not the mainland portion. The danger is proportion, not the mainland client.

What this means for you

Two changes, and where they bite.

Each decides whether a revenue stream sits inside or outside your 0% rate.

Change 01 · Mainland-billed services

A mainland invoice is non-qualifying, free zone licence or not.

A free zone consultancy, agency, or IT firm billing mainland clients cannot treat that revenue as eligible for 0%. This is the change most likely to move a number you thought was settled. A goods seller hits customs and an importer of record, so the exposure is obvious. A services firm bills straight from its licence with no friction, so non-qualifying income accrues unnoticed.

Most exposed: free zone service businesses
Change 02 · Dividend income

Dividends are categorised, not lumped into the split.

Qualifying dividends and profit distributions sit outside the corporate tax charge under the participation rules, not inside the qualifying or non-qualifying split that governs trading income. That protects holding companies: treating dividend receipts as non-qualifying revenue would erode the de minimis allowance and manufacture a breach where none exists. The outcome turns on the holding.

Who decides here: the facts of your structure
Who should check first

If this is you, your 0% rate is worth testing.

The most exposed never measured their mainland-facing income against the limit.

Free zone consultancies and agenciesMainland clients
IT and software firms billing the UAE marketService revenue
Anyone whose mainland share is risingProportion shift
Free zone holding companiesDividend treatment

The honest read. None of this means dropping mainland clients. It means measuring what proportion of your income they represent against the de minimis allowance as it accrues, not at year-end, and documenting the basis, because proving qualifying income is the taxpayer's burden. Testing it is cheap. Discovering the answer during an audit is not.

The firm's view

A QFZP position is not a status you claim once. It is a number you have to keep true.

We map every revenue stream to qualifying or non-qualifying and tell you plainly whether your 0% rate holds or whether the structure should move first. If the position is comfortable, we say so. If not, you find out while there is still time to act, the one point in the year when knowing is cheap.

In their words

Why founders bring the hard questions here.

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The questions we get

What free zone founders ask first.

Reviewed by Manish Kumar Pandey, Founder, DM Consultancy · Last reviewed June 2026

Does selling to a mainland customer cost me my whole 0% rate?

Not automatically. Income from services or goods supplied to a UAE mainland entity is non-qualifying, but a Qualifying Free Zone Person may earn a limited amount of non-qualifying (de minimis) revenue before its entire profit is pushed to the standard 9% rate. The clarification confirms mainland-facing service income counts toward that bucket, so a company doing heavy mainland work can breach the threshold and lose the 0% rate on all its income. Measure the proportion; do not assume.

Is dividend income qualifying income for a QFZP?

Dividends and profit distributions from shareholdings sit outside the corporate tax charge under the participation rules, not inside the QFZP regime as qualifying income. The Ministry of Finance clarification confirms how such income is categorised, so it is not mistakenly treated as non-qualifying revenue that erodes the de minimis allowance. Treatment depends on the nature of the holding, so confirm your structure with a qualified adviser.

Do I need to do anything if I already have QFZP status?

Review your revenue mix against the clarification before your next corporate tax return. Most free zone companies that assumed all their income qualified have never tested the mainland-facing portion against the de minimis limit. Map every revenue stream to qualifying or non-qualifying, document the basis, and keep that working with your records. This is not a small penalty; it changes the tax rate on your entire profit.

Want the full mechanics? Read our guide to QFZP status, or see how we handle assessment and filing on the corporate tax and VAT page. Last verified June 2026. Regulations change.

Your QFZP position, privately

Is your 0% rate still safe?
We will pressure-test it in one conversation.

Thirty minutes with Manish directly, no pitch. We weigh your mainland-facing income against the de minimis allowance and tell you plainly whether your rate holds or whether the structure should move first. If the firm fits your case, we proceed. If not, you leave with a clearer read on your exposure.

info@dm-uae.com · Port Saeed, Deira, Dubai