Does a Qualifying Free Zone Person need audited financial statements?
Yes. Every Qualifying Free Zone Person must have audited financial statements each year, no matter its revenue size, otherwise it can lose its 0% tax status.
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The detail
Under Article 2(1)(b) of Ministerial Decision No. 84 of 2025, a Qualifying Free Zone Person (QFZP) must prepare and maintain audited financial statements regardless of its revenue threshold. This is also a standing condition under Article 5(1)(b) of Ministerial Decision No. 229 of 2025 (and its predecessor MD 84 of 2025/MD 265 of 2023) for maintaining QFZP status; failing it disqualifies the person from QFZP status for that Tax Period and the following four.123
What the law says
- A QFZP must prepare and maintain audited financial statements as one of the conditions of Article 18(1) of the Corporate Tax Law.13
- Ministerial Decision 84 of 2025 confirms that all QFZPs must prepare audited financial statements, irrespective of revenue level (unlike the AED 50,000,000 threshold that applies to other Taxable Persons).2
- The FTA's Free Zone Persons guide confirms this obligation applies regardless of the QFZP's revenue.4 Based on FTA guidance
What it depends on
- Failure to meet this (or any other Article 18(1)) condition causes loss of QFZP status from the start of that Tax Period and for the following four Tax Periods.13
- A QFZP need not prepare separate financial statements for Qualifying and non-Qualifying Income, but must keep sufficient records to support the Qualifying Income calculation.4 Based on FTA guidance
Check before you rely on it
- Confirm audited financial statements are prepared for every Tax Period, not just when revenue exceeds AED 50 million.
- Check the audit covers the whole entity, even if separate Qualifying/non-Qualifying income statements aren't prepared.
Sources (4) — read the official text
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Article 5 – Other Conditions
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Article 5 – Other Conditions 1. In addition to the conditions set out in Clause (1) of Article (18) of the Corporate Tax Law, a Qualifying Free Zone Person must meet the following two conditions: a. Its non-qualifying Revenue does not exceed the de minimis requirements set out in Article (3) of this Decision. b. It prepares audited financial statements in accordance with any decision issued by the Minister on the requirements to prepare and maintain audited financial statements for the purposes of the Corporate Tax Law. 2. A Qualifying Free Zone Person that at any particular time during a Tax Period fails to meet any of the conditions set out in Clause (1) of Article (18) of the Corporate Tax Law and this Decision and any other conditions prescribed by the Minister shall cease to be a Qualifying Free Zone Person from the beginning of the relevant Tax Period and for the subsequent (4) four Tax Periods.
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Article 2 – Preparing and Maintaining Audited Financial
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Article 2 – Preparing and Maintaining Audited Financial Statements 1. For the purposes of Clause (2) of Article (54) of the Corporate Tax Law, all of the following shall prepare and maintain audited financial statements: a. A Taxable Person that is not a Tax Group and that derives Revenue exceeding AED 50,000,000 (fifty million United Arab Emirates dirhams) during the relevant Tax Period. b. A Qualifying Free Zone Person. 2. For the purposes of Clause (2) of Article (54) of the Corporate Tax Law and Article (3) of Ministerial Decision No. 114 of 2023 referred to above, a Tax Group shall prepare and maintain audited special purpose financial statements in accordance with the form, procedures and rules specified by the Authority. 3. Without prejudice to Clause (1) of this Article, a Qualifying Free Zone Person engaged in the activity of distribution of goods or materials in or from a Designated Zone in accordance with Ministerial Decision No. 265 of 2023 referred to above shall comply with any additional procedures prescribed by the Authority. 4. For the purposes of calculating the Revenue threshold specified in Clause (1) of this Article for a Non-Resident Person, only Revenue derived through Permanent Establishments and/or nexuses in the State shall be taken into account.
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Article 5 - Other Conditions
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Article 5 - Other Conditions 1. In addition to the conditions set out in Clause (1) of Article (18) of the Corporate Tax Law, a Qualifying Free Zone Person must meet the following two conditions: Ministerial Decision No. 229 of 2025 – As published by the Ministry of Finance 11 a. Its non-qualifying Revenue does not exceed the de minimis requirements set out in Article (3) of this Decision. b. It prepares audited financial statements in accordance with Ministerial Decision No. 84 of 2025 referred to above and any decision that amends or replaces it. 2. A Qualifying Free Zone Person that at any particular time during a Tax Period fails to meet any of the conditions set out in Clause (1) of Article (18) of the Corporate Tax Law and this Decision and any other conditions prescribed by the Minister shall cease to be a Qualifying Free Zone Person from the beginning of the relevant Tax Period and for the subsequent (4) four Tax Periods.
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Read the article
relevant Tax Period, or Cash Basis of Accounting where the relevant conditions are met.136 12.4. Preparing audited Financial Statements A Free Zone Person is required to prepare and maintain audited Financial Statements for Corporate Tax purposes (regardless of its Revenue) as a condition of being a QFZP.137 A QFZP is not required to prepare separate Financial Statements for its Qualifying Income and its other income and is also not required to prepare separate audited financial statements for any branches that it may have. However, the QFZP should have sufficient documentation to demonstrate how it calculated its Qualifying Income. 12.5. Tax Return and Corporate Tax payment Corporate Tax is a self-assessed regime. A Free Zone Person is required to pay Corporate Tax (if any) and file their Tax Return to the FTA in the form and manner prescribed by the FTA within 9 months from the end of the relevant Tax Period. 138 136 Articles 2 and 4 of Ministerial Decision No. 114 of 2023. 137 Article 54(2) of the Corporate Tax Law read with Article 5(1)(b) of Ministerial Decision No. 265 of 2023 and Article 2(2) of Ministerial Decision No. 82 of 2023. 138 Articles 48 and 53(1) of the Corporate Tax Law. Corporate Tax Guide | Free Zone Persons | CTGFZP1 133
Written by AI from the FTA sources above and checked before display. Not tax advice or official FTA information - confirm with a tax adviser before you act. Full disclaimer
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