Federal Decree-Law No. (47) of 2022 on the Taxation of Corporations and Businesses
Federal Decree-Law No. (47) of 2022
The UAE Corporate Tax Law establishes federal taxation of corporations and businesses, including taxable persons, exemptions, taxable income, reliefs, deductions, transfer pricing, tax losses, groups, free-zone rules, filing and payment.
Overview
What this legislation covers
The UAE Corporate Tax Law establishes federal taxation of corporations and businesses, including taxable persons, exemptions, taxable income, reliefs, deductions, transfer pricing, tax losses, groups, free-zone rules, filing and payment.
Who or what it applies to
- Resident juridical persons incorporated/recognised in the UAE, subject to exemptions.
- Certain foreign juridical persons effectively managed and controlled in the UAE.
- Non-Resident Persons with a Permanent Establishment, UAE nexus or State-sourced income as provided by law.
- Natural persons conducting Business or Business Activities when statutory conditions/thresholds are met.
- Free-zone persons, subject to the general law and special Qualifying Free Zone Person provisions.
Key points
Important points at a glance
Applies for Tax Periods beginning on or after 1 June 2023.
Defines Resident and Non-Resident Persons and the scope of taxable presence/nexus.
Provides exemptions for specified government entities, qualifying public benefit entities, investment funds and other statutory categories.
Regulates taxable income starting from accounting income with statutory adjustments.
Contains participation exemption and other exempt-income rules.
Contains Small Business Relief and qualifying restructuring/business-transfer relief mechanisms where conditions are met.
Regulates deductible expenditure and specific deduction limitations, including interest-related rules.
Contains transfer-pricing rules based on the arm's-length principle and related-party / connected-person requirements.
Regulates tax losses, transfers/utilisation and continuity restrictions.
Creates Tax Group rules for qualifying resident juridical persons.
Contains the Qualifying Free Zone Person framework and special tax treatment subject to conditions.
Sets corporate tax rates and the calculation of tax payable.
Regulates foreign tax credits and withholding-tax concepts.
Requires registration, returns, payment, records and transfer-pricing documentation where applicable.
Contains General Anti-Abuse Rules and transitional provisions.
Federal Decree-Law No. (60) of 2023 amended the law; numerous Cabinet/Ministerial decisions continue to implement it.
Practical explanation
Understanding the law
Purpose and practical effect
The UAE Corporate Tax Law establishes federal taxation of corporations and businesses, including taxable persons, exemptions, taxable income, reliefs, deductions, transfer pricing, tax losses, groups, free-zone rules, filing and payment.
Who the law applies to
- Resident juridical persons incorporated/recognised in the UAE, subject to exemptions.
- Certain foreign juridical persons effectively managed and controlled in the UAE.
- Non-Resident Persons with a Permanent Establishment, UAE nexus or State-sourced income as provided by law.
- Natural persons conducting Business or Business Activities when statutory conditions/thresholds are met.
- Free-zone persons, subject to the general law and special Qualifying Free Zone Person provisions.
Key definitions
- Taxable Person: a person subject to Corporate Tax under the decree-law.
- Resident Person and Non-Resident Person: status concepts determining the scope of taxation.
- Permanent Establishment: a taxable presence determined under the statutory PE rules.
- Qualifying Free Zone Person: a Free Zone Person satisfying the law and implementing conditions for special tax treatment.
- Taxable Income: accounting income adjusted under the Corporate Tax Law.
Main rights, duties and legal consequences
- Taxable Persons may claim exemptions, reliefs, deductions, tax losses and credits where conditions are satisfied.
- Taxable Persons must register, keep records, submit returns and pay tax within the statutory framework.
- Related-party transactions must satisfy the arm's-length standard.
- Tax groups and qualifying restructurings require statutory eligibility and elections/administration.
Practical compliance / procedure checklist
- Determine the person's tax status and whether an exemption or free-zone regime applies.
- Determine the Tax Period and prepare financial statements/accounting income.
- Apply tax adjustments, exempt income, reliefs, deductions, losses and transfer-pricing rules.
- Register with the FTA and keep records/documentation.
- Submit the corporate tax return and pay Corporate Tax within the statutory deadline.
- Review related Cabinet/Ministerial/FTA decisions for the relevant tax year because the implementation framework evolves frequently.
Deadlines and effective dates
- Corporate Tax applies to Tax Periods beginning on or after 1 June 2023.
- Registration deadlines are set by FTA decisions and depend on the person's type/incorporation status.
- Corporate Tax returns and payment are generally due under the statutory post-period framework; verify the exact deadline for the relevant Tax Period.
- Record retention and transfer-pricing documentation periods are governed by the Corporate Tax Law, Tax Procedures Law and implementing decisions.
Enforcement, violations and penalties
The Corporate Tax Law is administered through the Federal Tax Authority and the Tax Procedures Law. Administrative penalties, tax assessments, audits, collection and dispute procedures are governed largely by the Tax Procedures framework and implementing decisions.
Practical scenarios
- A UAE LLC with a calendar financial year first entered the Corporate Tax regime for the year beginning 1 January 2024, not 1 June 2023.
- A free-zone company must test every Qualifying Free Zone Person condition rather than assume a zero rate solely from its location.
- A group restructuring may qualify for relief only if all statutory continuity and election conditions are met.
- Payments between related companies should be supported by arm's-length transfer-pricing analysis where applicable.
Amendments and implementation
The law has been amended, including by Federal Decree-Law No. (60) of 2023, and is supplemented by an extensive and evolving set of Cabinet, Ministerial and FTA decisions.
Legal research caution
The principal federal statute, its amendments, Executive Regulations, Cabinet/Ministerial/FTA/MOHRE/TDRA decisions and sector-specific rules can operate together. Commentary in this file explains practical operation but does not create duties beyond enacted law. Always confirm the current version applicable to the date and facts in question.
Research status
Official-source review for this package was updated on 2026-09-07.
Practical notes
- Use the official current Arabic text for interpretation and application; the English package is a structured legal-information rendering.
- Verify the current consolidated version and related regulations immediately before a filing, transaction, enforcement decision or court submission.
- Exact penalties, thresholds, exceptions and procedural deadlines must be checked against the exact current article and implementing instrument.
- The supplied cover artwork is used as an editorial cover only and is not a source of legal authority.
Legislation text
Text and provisions
Official-text notice. This file is a comprehensive structured English legal-information rendering based on the official UAE sources listed in this package. It is not presented as a verbatim legally controlling English reproduction. For interpretation and application, consult the original Arabic text, the Official Gazette and the latest consolidated official legislation. Exact offence elements, penalties, exceptions, thresholds and deadlines must be checked against the current article.
Federal Decree-Law No. (47) of 2022 on the Taxation of Corporations and Businesses
Verified legislative metadata
| Instrument | Federal Decree-Law No. (47) of 2022 |
|---|---|
| Issued | 2022-12-09 |
| Effective | 2023-06-01 |
| Status | Active / in force, as amended |
| Official source | Official UAE source |
Legislative purpose and coverage
The UAE Corporate Tax Law establishes federal taxation of corporations and businesses, including taxable persons, exemptions, taxable income, reliefs, deductions, transfer pricing, tax losses, groups, free-zone rules, filing and payment.
Complete statutory structure and principal provisions
Chapter 1 — General provisions
Defines terms, purpose and tax concepts used throughout the law.
Taxable Person and basis of taxation
Identifies Resident and Non-Resident Persons and the taxable bases applicable to each.
Exempt Persons
Defines government and other exempt categories and conditions for maintaining exemption.
Free Zone Persons
Regulates Qualifying Free Zone Persons and the conditions for the special rate/treatment.
Taxable Income
Starts from accounting income and applies statutory tax adjustments, realisation concepts and elections.
Exempt Income and reliefs
Covers participation exemption, foreign permanent establishment exemption and specified relief mechanisms.
Deductions
Regulates deductible business expenditure and restrictions for non-business, capital, entertainment, interest and other categories.
Related Parties and Transfer Pricing
Requires arm's-length pricing, comparability analysis and documentation/disclosure in applicable cases.
Tax Losses
Regulates carry-forward, utilisation and transfer of tax losses subject to ownership/business continuity and other conditions.
Tax Groups
Allows qualifying UAE group companies to form a Tax Group and be treated under the group provisions.
Tax rates and calculation
Sets the corporate tax rate structure and calculation of tax payable, including special free-zone treatment.
Foreign Tax Credit
Allows relief for qualifying foreign taxes subject to statutory limits.
Registration, return and payment
Requires Tax Registration, returns and tax payment under the Tax Procedures framework.
Anti-Abuse and administration
Contains General Anti-Abuse Rules and powers to issue implementing decisions.
Chapter 20 — Final provisions / Article 70
Provides publication/commencement mechanics; the regime applies to Tax Periods commencing on or after 1 June 2023.
Key statutory points
- Applies for Tax Periods beginning on or after 1 June 2023.
- Defines Resident and Non-Resident Persons and the scope of taxable presence/nexus.
- Provides exemptions for specified government entities, qualifying public benefit entities, investment funds and other statutory categories.
- Regulates taxable income starting from accounting income with statutory adjustments.
- Contains participation exemption and other exempt-income rules.
- Contains Small Business Relief and qualifying restructuring/business-transfer relief mechanisms where conditions are met.
- Regulates deductible expenditure and specific deduction limitations, including interest-related rules.
- Contains transfer-pricing rules based on the arm's-length principle and related-party / connected-person requirements.
- Regulates tax losses, transfers/utilisation and continuity restrictions.
- Creates Tax Group rules for qualifying resident juridical persons.
- Contains the Qualifying Free Zone Person framework and special tax treatment subject to conditions.
- Sets corporate tax rates and the calculation of tax payable.
- Regulates foreign tax credits and withholding-tax concepts.
- Requires registration, returns, payment, records and transfer-pricing documentation where applicable.
- Contains General Anti-Abuse Rules and transitional provisions.
- Federal Decree-Law No. (60) of 2023 amended the law; numerous Cabinet/Ministerial decisions continue to implement it.
Amendments, executive regulations and related legislation
The law has been amended, including by Federal Decree-Law No. (60) of 2023, and is supplemented by an extensive and evolving set of Cabinet, Ministerial and FTA decisions.
Reading rule for case-specific use
This structured rendering is designed to give the website a complete substantive map of the legislation and its operative areas. Where a legal conclusion turns on precise wording, an article number, a penalty, an exception, an implementing decision or a transitional rule, the official Arabic text and current related legislation must be used before reliance.
Verification
Official source & references
Official legislation sourcehttps://uaelegislation.gov.ae/en/legislations/1582Open ↗This page is a research and educational resource. Legislation can be amended, repealed, supplemented by regulations or interpreted by courts and authorities. Obtain advice before relying on it for a live matter.