FTA updates procedures for Corporate Tax exemptions

Created By : Yeeshu Sehgal | UAE Tax Lead

Key highlights

FTA Decision No. 15 of 2026 replaces the 2023 rules on Corporate Tax exemptions and resets how entities register for, and apply for, exemption.

Most eligible entities get 90 Business Days from the end of their Tax Period to apply.

Two transitional deadlines are worth diarising - 31 October and 31 December 2026 - for certain retrospective claims. The new rules reach back to Tax Periods starting on or after 1 June 2023, though the application itself must be filed on or after 15 September 2026.

Background

Decision No. 15 of 2026 takes effect on 15 September 2026 and replaces the FTA’s 2023 guidance on Corporate Tax exemptions. It sits alongside the Corporate Tax Law and the Cabinet and Ministerial Decisions that actually define who qualifies for exemption; it does not create a new exempt category of its own.

Its real purpose is procedural – setting out how and when entities register, apply, and have their exemption backdated.

Key provisions

1. Corporate Tax registration and exemption application

Entities under Article 4(1) of the Corporate Tax Law must still register for Corporate Tax in the normal way. Once that registration is approved, those falling within categories (f), (g), (h) and (i) can apply for exemption, provided the relevant conditions are met.

2. General exemption application deadline

Applications open only after the relevant Tax Period ends, and must be filed within 90 Business Days of that date.

3. Transitional deadlines

Some categories get more time, though the cut-off is firm. Entities within Cabinet Decision No. 55 of 2025 must apply by 31 December 2026, as must certain juridical persons eligible under Article 5 of Cabinet Decision No. 34 of 2025, for Tax Periods that began in 2025.

Other important provisions

4. Wholly-owned entities

A subsidiary within Article 4(1)(h) or (i), wholly owned and controlled by an already-eligible exempt person, can apply for its own exemption once the parent has applied. The FTA holds off deciding the subsidiary’s application until the parent’s has been approved.

5. Specific deadline for certain historical Tax Periods

There’s a separate route for an Article 4(1)(h) entity wholly owned and controlled by an Article 4(1)(a) or (b) person: exemption for a Tax Period that ended before 1 January 2026 can still be claimed, but the application must be in by 31 October 2026, with evidence that the conditions were met for that period.

6. Effective date of exemption

An approved exemption usually takes effect from the start of the Tax Period stated in the application. The FTA can pick a different start date in certain situations – an incorrect Tax Period on the form, an acquisition partway through the period, or exemption legislation that itself applies retrospectively.

7. Repeal and application

FTA Decision No. 7 of 2023 is repealed from 15 September 2026. The replacement Decision covers Tax Periods from 1 June 2023 onwards, but only applies to exemption applications submitted on or after 15 September 2026.

Key dates

What should businesses consider?

• Identify which entities could qualify for exemption under Article 4(1) and the relevant Cabinet Decisions.
• Check that registration and exemption applications have been filed in the correct order – registration first, exemption second.
• Revisit Tax Periods from 1 June 2023 onwards for any retrospective exemption opportunities.
• Note the 31 October and 31 December 2026 deadlines wherever they apply.
• Hold on to documentation that evidences the exemption conditions were actually satisfied.

How AKM Global can assist

We assess whether your entities qualify for exemption, review historical Tax Periods for retrospective claims, map out the applicable deadlines, and prepare and file the exemption applications on your behalf.

Conclusion

Decision No. 15 of 2026 tightens the process for Corporate Tax exemptions and sets firm deadlines for retrospective claims. If any of your entities could be exempt, this is a good moment to check registration status, confirm eligibility, and get the relevant deadlines on the calendar.