Last Updated: 2 October 2026
The UAE Corporate Tax regime continues to evolve as the Federal Tax Authority (FTA) issues new decisions and procedures to clarify compliance requirements for businesses and other entities.
A significant recent development is FTA Decision No. 15 of 2026 on Provisions on Exemption from Corporate Tax, which provides important rules regarding Corporate Tax registration, exemption applications, application deadlines and the effective date of Corporate Tax exemption.
The Decision was issued on 8 September 2026, published on 15 September 2026, and became effective from 15 September 2026. It also repeals FTA Decision No. 7 of 2023 from its effective date.
For UAE companies, investment structures, qualifying entities and persons seeking Corporate Tax exemption, understanding these procedures is important because an exemption is not necessarily automatic. In specified cases, the person must first complete Corporate Tax registration and then apply for exemption with the Federal Tax Authority.
This article explains the key provisions of FTA Decision No. 15 of 2026 in simple language.
FTA Decision No. 15 of 2026 sets out the procedures and timelines for obtaining exemption from UAE Corporate Tax for persons covered by the relevant provisions of the UAE Corporate Tax Law.
The Decision works together with the UAE Corporate Tax legislation and relevant Cabinet Decisions, including provisions dealing with exempt persons, qualifying investment funds, qualifying limited partnerships and other categories recognised under the Corporate Tax framework.
The main areas covered by the Decision include:
Corporate Tax registration before exemption application in specified cases
Procedure for applying for Corporate Tax exemption
90 Business Day application deadline
Special deadlines for certain retrospective exemption applications
31 December 2026 deadline in specified cases
31 October 2026 deadline for a specific category of juridical persons
Effective date of an approved exemption
Transitional application of the Decision
Repeal of the earlier FTA Decision No. 7 of 2023
One of the important points under the new FTA Decision is that certain persons seeking Corporate Tax exemption must first apply for Corporate Tax registration within the prescribed timeline.
The Decision specifically addresses persons falling within certain categories under Article 4 of the UAE Corporate Tax Law.
Once the Federal Tax Authority approves the Tax Registration application, certain eligible persons may then submit an application for Corporate Tax exemption, provided that they satisfy the relevant exemption conditions.
Corporate Tax registration and Corporate Tax exemption are two separate steps in applicable cases.
A business or entity should therefore not assume that being potentially exempt means that it can simply ignore Corporate Tax registration requirements.
The registration requirement should be reviewed based on the entity’s legal status, category and applicable provisions.
Corporate Tax exemption is available only to persons and entities that fall within the categories and conditions specified under the UAE Corporate Tax legislation.
The exemption framework can cover specific categories such as qualifying investment structures, certain public benefit entities, certain entities covered by Cabinet Decisions and other categories recognised under the Corporate Tax Law.
Importantly, not every UAE company is automatically exempt from Corporate Tax.
For example, simply being:
a Free Zone company;
a small company;
a company with low revenue;
a newly incorporated company; or
a company with no employees
does not by itself mean that the company is exempt from UAE Corporate Tax.
The actual exemption category and conditions must be examined.
FTA Decision No. 15 of 2026 provides a general timeline for certain exemption applications.
Where a person falls within the specified exemption categories, the exemption application must generally be submitted:
after the end of the Tax Period in which the person met the exemption conditions, and no later than 90 Business Days from the end of that Tax Period.
For the purpose of this Decision, a Business Day means a day of the week other than:
weekends; and
official UAE Federal Government holidays.
Therefore, the 90-day period should not simply be treated as 90 calendar days.
Suppose an eligible entity satisfies all exemption conditions during its Tax Period ending on 31 December 2026.
The entity should review the applicable exemption procedure and submit its application within the prescribed period following the end of that Tax Period.
Businesses should maintain a proper compliance calendar so that the exemption application deadline is not missed.
FTA Decision No. 15 of 2026 contains special rules for certain persons who may be eligible for exemption with retrospective effect.
For persons covered by Cabinet Decision No. 55 of 2025, the exemption application must be submitted no later than:
This is an important date for eligible persons who may qualify for retrospective Corporate Tax exemption under the relevant legislation.
Businesses and advisers should therefore identify whether the entity falls within the scope of Cabinet Decision No. 55 of 2025 and whether the relevant exemption conditions have been satisfied.
Missing a specific statutory or regulatory deadline can create unnecessary Corporate Tax compliance issues.
FTA Decision No. 15 of 2026 also provides a specific transitional deadline for certain juridical persons entitled to apply for exemption under Article 5 of Cabinet Decision No. 34 of 2025.
This applies to relevant Tax Periods that:
commenced during calendar year 2025; and
ended on or before 31 August 2026.
For qualifying cases covered by this provision, the exemption application must be submitted no later than:
This provision is particularly relevant to structures involving Qualifying Limited Partnerships and certain wholly owned and controlled juridical persons.
The eligibility conditions under Cabinet Decision No. 34 of 2025 should be reviewed carefully before making an exemption application.
There is another important deadline under FTA Decision No. 15 of 2026.
A juridical person covered by the specific provision may apply for exemption in respect of a Tax Period that ended before 1 January 2026.
The application must be submitted no later than:
However, this is not a general deadline applicable to all UAE companies.
The provision applies to a specific juridical person that is:
wholly owned and controlled by a person falling within specified exempt categories; and
seeking exemption for a qualifying earlier Tax Period; and
able to satisfy the relevant exemption conditions for that Tax Period.
Therefore, companies should not assume that the 31 October 2026 deadline applies to every entity.
The ownership structure and exemption category should be checked before relying on this provision.
FTA Decision No. 15 of 2026 also addresses certain juridical persons that are wholly owned and controlled by another eligible person.
In specified circumstances, the subsidiary or wholly owned juridical person may submit its own exemption application.
However, where the rules require the parent or controlling person to apply first, the Federal Tax Authority will not make a decision on the subsidiary’s application until the relevant application of the parent or controlling person has been approved.
This means that ownership and control are not merely corporate-law considerations.
They can also be important for determining whether an entity qualifies for Corporate Tax exemption and when its exemption application can be processed.
Companies should therefore review:
shareholding;
beneficial ownership;
control;
legal structure;
relationship between parent and subsidiary; and
exemption status of the controlling entity.
Once the Federal Tax Authority approves an exemption application, the exemption will generally become effective from the start of the Tax Period specified in the application.
This is an important feature of the Decision.
However, the FTA may determine a different effective date in certain circumstances.
For example, an alternative effective date may be relevant where:
the Tax Period stated in the registration form is incorrect;
the applicant has been acquired during a Tax Period and the relevant conditions are satisfied only from a later Tax Period;
incorrect Tax Period information was included in the exemption application;
supporting evidence shows that the exemption conditions were actually satisfied during a subsequent Tax Period; or
relevant legislation provides for retrospective application.
Therefore, the exemption effective date should not be assumed without reviewing the relevant application and supporting information.
An important transitional provision is included in Article 5 of the Decision.
FTA Decision No. 15 of 2026 applies to Tax Periods commencing on or after 1 June 2023, where the exemption application is submitted to the Federal Tax Authority on or after the effective date of the Decision.
This means the Decision can be relevant to certain earlier Tax Periods, provided the application is submitted after 15 September 2026 and the applicable conditions are satisfied.
Businesses should therefore review historical Tax Periods where they believe they may have been eligible for Corporate Tax exemption.
FTA Decision No. 15 of 2026 specifically repeals:
FTA Decision No. 7 of 2023 on the Provisions of Exemption from Corporate Tax
The repeal takes effect from the effective date of the new Decision.
Therefore, taxpayers and tax advisers reviewing Corporate Tax exemption applications should refer to the current framework under FTA Decision No. 15 of 2026, together with the underlying Corporate Tax Law and relevant Cabinet and Ministerial Decisions.
Before applying for Corporate Tax exemption, the taxpayer should carry out a detailed review of its legal and tax position.
Depending on the exemption category, relevant information may include:
Trade licence
Certificate of incorporation
Memorandum and Articles of Association
Shareholding details
Ownership structure
Beneficial ownership information
Board or shareholder documents where relevant
Corporate Tax registration details
Tax Registration Number
Tax Period details
Previous Corporate Tax filings, where applicable
Previous exemption applications, where applicable
Financial statements
Accounting records
General ledger
Trial balance
Investment records
Supporting schedules
Shareholder register
Group structure
Parent-company documents
Ownership percentages
Control arrangements
The exact documents required will depend on the exemption category and the facts of the particular taxpayer.
This is one of the most important points for UAE businesses.
A company or entity that qualifies for Corporate Tax exemption should still carefully review its compliance obligations.
Depending on the circumstances, an entity may have obligations relating to:
Corporate Tax registration
Corporate Tax exemption application
Tax records
Accounting records
Financial statements
Supporting documents
VAT registration and VAT returns
Economic substance or other regulatory requirements where applicable
Other UAE business compliance requirements
Therefore:
Exempt from Corporate Tax does not automatically mean exempt from every UAE tax or regulatory requirement.
Each obligation must be examined separately.
Businesses applying for UAE Corporate Tax exemption should avoid the following common mistakes.
Being within a potentially exempt category does not mean that every entity automatically receives exemption.
The applicable conditions must be satisfied.
Certain exempt persons are required to register for Corporate Tax before applying for exemption.
The exemption application timeline should be monitored carefully.
Different Cabinet Decisions and provisions apply to different types of persons and structures.
The transitional provisions may make the Decision relevant to earlier Tax Periods.
For certain entities, ownership and control can directly affect exemption eligibility.
Incorrect Tax Period information can affect the effective date of exemption.
Before submitting an exemption application, businesses should consider the following checklist:
| Compliance Point | Review Required |
|---|---|
| Corporate Tax registration | Check whether registration is required |
| Exemption category | Identify the correct legal provision |
| Tax Period | Confirm the applicable Tax Period |
| Eligibility conditions | Verify all conditions |
| Ownership | Review shareholding and control |
| Supporting documents | Prepare evidence |
| 90 Business Day deadline | Calculate applicable deadline |
| 31 October 2026 deadline | Check whether the specific transitional rule applies |
| 31 December 2026 deadline | Check whether the retrospective provisions apply |
| Effective date | Confirm the correct Tax Period |
| Historical periods | Review earlier Tax Periods |
| FTA application | Submit through the prescribed process |
Businesses and entities that believe they may qualify for UAE Corporate Tax exemption should not wait until the last moment.
A practical approach is to:
Determine whether the entity is a company, investment structure, public benefit entity, qualifying partnership or another category.
Check whether the entity has registered for UAE Corporate Tax and whether registration was completed within the prescribed timeline.
Determine exactly which provision of the Corporate Tax Law or relevant Cabinet Decision provides the potential exemption.
Review the conditions applicable to that exemption category.
Check whether the entity may qualify for exemption for an earlier Tax Period.
Determine whether the application falls under:
the general 90 Business Day rule;
the 31 October 2026 transitional deadline;
the 31 December 2026 deadline; or
another specific deadline applicable under the relevant legislation.
Maintain sufficient documentation to demonstrate that the exemption conditions have been satisfied.
Submit the exemption application through the applicable FTA process and retain the application and supporting records.
This update is also relevant to businesses and entrepreneurs in India who own or control UAE companies.
Many Indian entrepreneurs operate businesses in:
Dubai
Abu Dhabi
Sharjah
Ajman
Ras Al Khaimah
Fujairah
Umm Al Quwain
Some Indian business owners also establish UAE entities for international trading, consulting, investment, holding or regional operations.
For such businesses, UAE Corporate Tax compliance should be reviewed together with the company’s:
UAE legal structure;
ownership;
accounting records;
Corporate Tax registration;
Tax Period;
exemption eligibility;
VAT position; and
India-UAE cross-border tax considerations.
A UAE company should not assume that incorporation in a Free Zone or ownership by an Indian resident automatically creates a Corporate Tax exemption.
The actual facts and applicable UAE legislation need to be examined.
No. Where the legislation requires an application, the eligible person must follow the prescribed registration and exemption application process and satisfy the applicable conditions.
For certain categories covered by the Decision, yes. The entity must first apply for Corporate Tax registration within the prescribed timeline before submitting the exemption application.
For the relevant categories covered by the general rule, the application must generally be submitted after the end of the Tax Period in which the exemption conditions were met and within 90 Business Days from the end of that Tax Period.
Certain retrospective exemption applications covered by the relevant provisions must be submitted by 31 December 2026.
It applies to a specific category of wholly owned and controlled juridical persons seeking exemption for qualifying Tax Periods that ended before 1 January 2026, subject to the prescribed conditions.
No. It is a specific transitional provision and should not be treated as a general Corporate Tax exemption deadline.
Yes. FTA Decision No. 7 of 2023 is repealed from the effective date of FTA Decision No. 15 of 2026.
In specified circumstances, yes. The Decision contains provisions dealing with retrospective exemption applications and transitional situations. The precise eligibility requirements must be checked.
No. Free Zone status by itself does not automatically mean that a company is exempt from UAE Corporate Tax. The applicable Corporate Tax rules and conditions must be examined.
Yes, where the UAE company may fall within an exemption category or transitional provision. The UAE company’s registration, ownership, Tax Period and exemption conditions should be reviewed.
FTA Decision No. 15 of 2026 is an important development in the UAE Corporate Tax compliance framework.
The Decision provides greater clarity on the procedure for Corporate Tax exemption, Corporate Tax registration, exemption application timelines, retrospective exemption and effective dates.
Businesses should pay particular attention to the 90 Business Day rule, as well as the special 31 October 2026 and 31 December 2026 deadlines where applicable.
The most important practical point is that taxpayers should identify their exact exemption category and Tax Period before deciding which deadline or procedure applies.
If your UAE company, investment structure, partnership or other entity may qualify for Corporate Tax exemption, a detailed review should be undertaken before submitting an application to the Federal Tax Authority.
IGSK Corporate Tax Advisors provides UAE-focused tax and accounting advisory services for businesses, entrepreneurs and international clients.
Our services include:
UAE Corporate Tax registration
Corporate Tax return assistance
Corporate Tax exemption assessment
UAE VAT registration and compliance
UAE bookkeeping and accounting
Financial statement preparation
Tax compliance review
Free Zone and Mainland business advisory
India–UAE tax and business advisory
UAE business setup and accounting support
IGSK Corporate Tax Advisors
Disclaimer: This article is for general informational purposes and should not be treated as legal or tax advice. Corporate Tax exemption eligibility depends on the taxpayer’s specific facts, legal structure, Tax Period and applicable UAE legislation. Businesses should review the current FTA legislation and obtain professional advice before taking compliance decisions.
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