Does every free zone company need to register for Corporate Tax?

Article 11 – Taxable Person 1. Corporate Tax shall be imposed on a Taxable Person at the rates determined under this Decree-Law. 2. For the purposes of this Decree-Law, a Taxable Person shall be either a Resident Person or a Non-Resident Person. Federal Decree-Law No. 47 of 2022 and its amendments – Unofficial translation (as published by the Ministry of Finance) 16 3. A Resident Person is any of the following Persons: a. A juridical person that is incorporated or otherwise established or recognised under the applicable legislation of the State, including a Free Zone Person. b. A juridical person that is incorporated or otherwise established or recognised under the applicable legislation of a foreign jurisdiction that is effectively managed and controlled in the State. c. A natural person who conducts a Business or Business Activity in the State. d. Any other Person as may be determined in a decision issued by the Cabinet at the suggestion of the Minister. 4. A Non-Resident Person is a Person who is not considered a Resident Person under Clause 3 of this Article and that either: a. Has a Permanent Establishment in the State as under Article 14 of this Decree-Law. b. Derives State Sourced Income as under Article 13 of this Decree-Law. c. Has a nexus in the State as specified in a decision issued by the Cabinet at the suggestion of the Minister. 5. A branch in the State of a Person referred to in Clause 3 of this Article, shall be treated as one and the same Taxable Person. 6. The Cabinet shall, upon a suggestion of the Minister and in coordination with the relevant competent authorities, issue a decision specifying the categories of Business or Business Activity conducted by a resident or non-resident natural person that are subject to Corporate Tax under this Decree-Law.

If the Taxable Person believes a field is relevant to them but it does not appear in their Tax Return, the Taxable Person needs to ensure that the information which they have provided during the Tax Registration process was correct. In addition, the Taxable Person will also need to ensure that the responses in the fields in the Tax Return are correct. If a Person who has registered for Corporate Tax purposes falls out of scope of Corporate Tax by virtue of a Double Taxation Agreement, this will be established at the Taxable Person details section of the guide (see Section 4). The Person will consequently not be required to complete a full Tax Return. 3.1. Taxable Person details This part of the Tax Return contains pre-populated data as well as fields that need to be completed by the Taxable Person. This enables EmaraTax to create a tailor-made Tax Return, showing each Taxable Person only the fields and schedules, which are potentially relevant. If any of the pre-populated data is incorrect, the Taxable Person will be directed to correct this information before proceeding with the completion of their Tax Return. For further information on this, see Section 4. The Tax Return caters for the following categories of Taxable Persons: • Juridical person that is a Resident Person. • Juridical person that is a Non-Resident Person (for example, a juridical person that is a Non-Resident Person with a UAE Permanent Establishment). • Natural person who is a Resident Person. • Natural person who is a Non-Resident Person (for example, a natural person who is a Non-Resident Person with a UAE Permanent Establishment). • Qualifying Free Zone Person. i.e. a Taxable Person that is located in the Free Zone and meets the conditions to be a Qualifying Free Zone Person. If a Taxable Person located in a Free Zone does not meet the conditions to be a Qualifying Free Zone Person or has elected not to be treated as a Qualifying Free Zone Person, it will complete the Tax Return as a juridical person that is a Resident Person or a Non-Resident Person, as the case may be. • Tax Group that has been approved by the FTA pursuant to an application submitted jointly by the Parent Company and each Subsidiary seeking to become members of the Tax Group. • Unincorporated Partnership that has received an approved application to be treated as a separate Taxable Person. • Exempt Persons. Exempt Persons are not required to complete a Tax Return unless (in certain limited circumstances and depending on the type of Exempt Person), they have a taxable Business, in which case they will be treated as a Taxable Person that is a Resident Person insofar as they conduct taxable Business, as explained in Section 23 below. Corporate Tax Guide | Tax Returns | CTGTXR1 21

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.

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.