Corporate tax amendments in the UAE: what changed and what it means for your business

What is the corporate tax amendment UAE businesses need to know about?

The corporate tax amendment UAE framework refers to updates made to Federal Decree-Law 47 of 2022, the country's main corporate tax law. Recent amendments introduced a 15% Domestic Minimum Top-up Tax (DMTT) for large multinationals from January 2025, refined small business relief, and clarified filing obligations. These changes affect how UAE companies calculate, report, and pay corporate tax.

The UAE introduced federal corporate tax under Federal Decree-Law 47 of 2022, effective for financial years starting on or after June 1, 2023. Since then, the Ministry of Finance (MoF) and the Federal Tax Authority (FTA) have issued several amendments and cabinet decisions to align UAE rules with global tax standards, including OECD Pillar Two. For a full overview of the regime, see our UAE Corporate Tax hub.

This article explains the key amendments, the rates that apply now, who is affected, and the practical steps UAE business owners and finance teams should take before their next filing.

The legal base: Federal Decree-Law 47 of 2022 and its amendments

Federal Decree-Law 47 of 2022 is the original corporate tax law. It sets the 9% standard rate, the 0% bracket up to AED 375,000 of taxable income, and the rules for free zone persons, exempt persons, and qualifying group relief.

Since 2022, the government has issued a series of cabinet decisions and ministerial decisions that refine the law. These do not replace the decree-law. They add detail on specific topics such as transfer pricing, qualifying free zone persons (QFZPs), and the DMTT.

Why amendments matter

UAE corporate tax is still a young regime. The amendments fix gaps, align the UAE with international standards, and respond to feedback from businesses. If you ignore them, you risk under-reporting income, missing deadlines, or losing free zone benefits.

Where to find the official text

Official amendments are published on the UAE Ministry of Finance and UAE Federal Tax Authority websites. Always check the FTA portal for the most recent guides and public clarifications before you file.

Key UAE corporate tax amendments at a glance

The table below summarises the main updates that UAE businesses should track. Use it as a quick reference.

The 9% rate is unchanged

The headline rate stays at 9% on taxable income above AED 375,000. Income up to AED 375,000 is taxed at 0%. This bracket helps small and medium businesses keep most of their early-stage profit.

The 15% DMTT is new

From January 1, 2025, multinational enterprise groups with consolidated global revenue of EUR 750M or more in at least two of the previous four years are subject to a 15% Domestic Minimum Top-up Tax. This aligns the UAE with the OECD Pillar Two global minimum tax rules.

Small business relief: still available, with conditions

Small business relief lets a resident juridical person elect to be treated as having no taxable income for a tax period, if revenue does not exceed AED 3M in that period and all previous tax periods. The relief is available for tax periods ending on or before December 31, 2026.

Who can claim it

You must be a resident person. You cannot be a member of a multinational group covered by the DMTT, and you cannot be a QFZP. You must still register with the FTA and file a corporate tax return, even if you elect for the relief.

What happens if revenue crosses AED 3M

If your revenue exceeds AED 3M in any tax period, you lose the relief for that period and for all future periods. You then apply the standard 0% and 9% rate structure. Plan ahead so a single strong year does not catch you off guard.

Free zone companies: QFZP status and amendments

Free zone businesses can still benefit from a 0% corporate tax rate on qualifying income if they meet the conditions to be a Qualifying Free Zone Person (QFZP). Recent cabinet decisions refine what counts as qualifying income, which activities are excluded, and how to handle transactions with mainland customers.

Core QFZP conditions

• Maintain adequate substance in the UAE.
• Earn qualifying income as defined by the cabinet decision.
• Do not elect to be subject to the standard 9% rate.
• Meet transfer pricing rules and prepare required documentation.
• Meet de minimis requirements on non-qualifying revenue.

What counts as qualifying income

Qualifying income generally includes transactions with other free zone persons and certain qualifying activities such as manufacturing, holding of shares, fund management, and treasury services for related parties. Income from mainland UAE customers is usually non-qualifying, with limited exceptions.

Filing, registration, and the practical impact of amendments

Every taxable person must register for corporate tax with the FTA and file a return, regardless of the rate that applies. The return is due within 9 months of the end of the financial year. For example, a financial year ending December 31, 2024 has a filing and payment deadline of September 30, 2025.

For step-by-step guidance, see our UAE Corporate Tax Return Guide and our walkthrough on how to file corporate tax return UAE. Check the UAE Corporate Tax Filing Deadline page to confirm dates that apply to your year end.

What changes in your filing because of the amendments

• If you are part of a large multinational group, you must assess DMTT exposure for periods starting January 1, 2025.
• If you claim small business relief, you must confirm revenue stayed under AED 3M.
• If you are a free zone company, you must document QFZP status and qualifying income.
• If you have related party transactions, you must keep transfer pricing files.

Fees, extensions, and payment

The FTA does not charge a separate filing fee, but late filing, late registration, and late payment trigger penalties. Read our notes on Corporate Tax Filing Fees UAE, Corporate Tax Extension UAE rules, and Corporate Tax Payment Methods UAE to plan cash flow.

Penalties and risk if you ignore the amendments

Administrative penalties under tax procedures law apply to late registration, late filing, late payment, and incorrect returns. Penalties can range from fixed amounts of a few thousand dirhams to percentage-based fines that grow over time. Repeated breaches can escalate quickly.

The biggest risks from missing the amendments are:

1. Failing to assess DMTT and under-paying tax in 2025 if you are a large multinational.
2. Losing QFZP status by missing a substance or income condition.
3. Claiming small business relief incorrectly and facing back tax plus penalties.
4. Missing transfer pricing documentation, which can trigger adjustments.

How the UAE compares to other Gulf regimes

The UAE rate of 9% on taxable income above AED 375,000 remains one of the most competitive in the region. The introduction of a 15% DMTT brings the UAE in line with OECD Pillar Two, which other countries are also implementing. Free zone benefits, properly maintained, continue to offer a clear advantage for international businesses based in the UAE.

Action checklist for UAE finance teams

• Confirm your tax period and filing deadline with the FTA.
• Check if your group is in scope for the 15% DMTT from January 1, 2025.
• Review small business relief eligibility against the AED 3M revenue test.
• Document QFZP conditions if you are in a free zone.
• Prepare or update transfer pricing files for related party transactions.
• Reconcile financial statements with taxable income adjustments.
• Set internal deadlines 30 to 60 days before the FTA due date.

For a deeper view across all topics, return to the UAE Corporate Tax hub. It links to every guide in this cluster.

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