United Arab Emirates MOF Issues Ministerial Decisions on Qualifying Income, Activities for Free Zone Entities

The Emirati Ministry of Finance Nov. 3 posted online Ministerial Decision Nos. 100/2023 and 265/2023, on determining qualifying income and activities of free zone entities, for corporate income tax purposes. The decisions include: 1) rules for determining qualifying and excluded activities of free zone entities; 2) the treatment of non-qualifying income; 3) taxation of income attributable to domestic and foreign permanent establishments (PEs) of free zone companies, and from immovable free zone properties; 4) determination of qualifying income derived from intellectual property, according to the OECD’s modified nexus approach; 5) the requirement that core income-generating activities occur in a free ...