- Ministerial Decision No. 229 of 2025 provides guidelines for free-zone businesses in the UAE.
- It clarifies qualifying and excluded activities for the 0% corporate tax regime.
- Introduces a 51% guardrail to differentiate trading from distribution.
- Establishes a de-minimis safe harbour for revenue.
- Sets rules for qualifying IP with a 30% R&D uplift.
- Emphasizes the need for revenue-mix modeling, contract reviews, and audit alignment.
- Highlights the importance of compliance to maintain tax advantages.
- Urges businesses to test current models against new rules quickly.
- Defines core qualifying activities like manufacturing, commodity trading, and asset management.
- Provides an action plan and scenarios to illustrate application.
Source: nrdoshi.ae
Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.
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