Corporate tax impact assessment
We work through how the law applies to each entity: which are taxable, which income is exempt, where the 9% falls and what the next return will show. The output is figures, with the principles behind them.
Plan · Advisory
Corporate tax advice before the numbers are fixed
The decisions that set a corporate tax bill are taken long before the return: where income sits, how the group is owned, when shares change hands. Our chartered accountants, with Big Four audit-firm experience, assess the impact, cost each option in AED and put the advice in writing for the board.
- Headline rate
- 9%
- on taxable income above AED 375,000
- R&D tax credit
- Up to 50%
- non-refundable, from 2026 tax periods, max AED 2m
- Loss offset cap
- 75%
- of taxable income in any one tax period
- Interest deduction
- 30%
- of EBITDA, or AED 12 million if higher
Plan
Who this is for
- Boards deciding whether a new activity belongs in a mainland company, a free zone entity or a separate subsidiary.
- Holding companies with UAE and foreign shareholdings that need dividends and gains to remain exempt.
- Groups carrying tax losses or significant debt, or facing a change of shareholders, that need to know what survives.
- Companies running R&D in the UAE that want to know whether 2026 spend can earn the new tax credit.
- CFOs who want a second opinion on a return prepared in-house or by another firm before the FTA forms its own view.
- Transactions that turn on a point the law does not settle, where a private clarification from the FTA may be worth requesting.
What we do
The work, end to end.
Mainland, free zone and holding structures
We compare structures on actual numbers. A Qualifying Free Zone Person (QFZP) pays 0% on qualifying income but has no AED 375,000 band on the rest, and a holding structure depends on whether dividends and gains qualify for exemption.
Computation planning
Losses, interest, entertainment and exempt income are where computations go wrong. We model the 75% loss cap, the 50% ownership continuity test, the interest limitation and the 50% entertainment restriction against your figures before year end.
R&D tax credit
We test projects against the OECD Frascati Manual definition of R&D, check the spend and headcount thresholds, and prepare the case for pre-approval by the Emirates Research and Development Council.
Second opinions
We review a return, a structure or another adviser's memo, and state plainly where we agree, where we do not and what an error would cost.
FTA private clarifications
Where the law is unclear on your facts, we help decide whether to ask the FTA directly, then draft and file the request under its updated clarification process.
FY2026 year-end planning
Before the year closes, we review the decisions that close with it: R&D claims, free zone distributor reporting, which entities and Tax Groups need audited financial statements, and Small Business Relief eligibility.
How it works
Clear steps. No guesswork.
- 1
Day 1
Initial conversation
At no charge, you set out the decision or the problem. We explain what the analysis involves and what we will need.
- 2
Typically 1 week
Facts and documents
Financial statements, trial balance, group chart, shareholder and loan agreements, and any earlier advice, shared through a secure link.
- 3
Typically 2 to 3 weeks
Analysis and modelling
We apply the law to the facts and model each option in AED, including those we would advise against.
- 4
Typically 1 week
Written advice
A memo with our conclusion, the reasoning, the legal references and the risks, followed by a meeting to take you through it.
- 5
Varies
Implementation
We support the follow-through: accounting entries, intercompany documents, the return position and, where needed, a clarification request to the FTA.
What you get
Deliverables
- A written advice memo with conclusions, reasoning and legal references
- A side-by-side model of each option's tax cost in AED
- A computation review covering losses, interest, entertainment and exempt income
- An R&D tax credit eligibility assessment, where relevant
- A drafted private clarification request, where one is worth filing
- An FY2026 year-end checklist with the dates that apply to each entity
Know the law
The rules in brief
- 1
Taxable income up to AED 375,000 is taxed at 0%, and the excess at 9%.
Federal Decree-Law No. 47 of 2022, Art. 3; Cabinet Decision No. 116 of 2022
- 2
Tax losses carry forward indefinitely but can offset no more than 75% of taxable income in a period, and survive only if at least 50% of the ownership is held continuously or the same or a similar business continues.
Federal Decree-Law No. 47 of 2022, Arts. 37 and 39
- 3
Net interest expense is deductible up to the higher of AED 12 million or 30% of EBITDA; any excess carries forward for 10 tax periods.
Federal Decree-Law No. 47 of 2022, Art. 30; Ministerial Decision No. 126 of 2023
- 4
Only 50% of entertainment expenditure is deductible.
Federal Decree-Law No. 47 of 2022, Art. 32
- 5
Under the participation exemption, a shareholding of at least 5%, or one that cost at least AED 4 million, held or intended to be held for 12 months or more, can qualify, subject to a subject-to-tax test benchmarked at 9% and other conditions.
Federal Decree-Law No. 47 of 2022, Art. 23; Ministerial Decision No. 302 of 2024
- 6
The R&D tax credit applies to tax periods starting on or after 1 January 2026, is non-refundable and is capped at AED 2 million per tax period.
Cabinet Decision No. 215 of 2025; Ministerial Decision No. 24 of 2026
- 7
The FTA's rules on clarification requests were amended with effect from 1 March 2026, and a new Private Clarifications guide followed in July 2026.
FTA Decision No. 2 of 2026; FTA Private Clarifications Guide (TPGPC1)
No. A Qualifying Free Zone Person pays 0% only on qualifying income, and 9% on everything else with no AED 375,000 band. If non-qualifying revenue exceeds 5% of total revenue or AED 5 million, whichever is lower, the company loses the regime for that tax period and the next four. Where most income falls outside the qualifying activities, a mainland company can cost the same or less, with fewer conditions to meet.
Losses carry forward only if at least 50% of the ownership is held continuously, or if the same or a similar business continues after a change of more than 50%. Listed companies are outside this test. Even losses that survive can offset only 75% of taxable income in a period, so a profitable year still pays some tax. We test the position before the deal is signed.
Net interest expense is deductible up to the higher of AED 12 million or 30% of EBITDA (earnings before interest, tax, depreciation and amortisation). Net interest of AED 12 million or less is not restricted by this cap, although it must still be deductible under the general rules. Anything the cap disallows carries forward for up to 10 tax periods. Banks, insurers and individuals are outside the rule.
Possibly, for tax periods starting on or after 1 January 2026. The credit is 15% of the first AED 1 million of qualifying spend, 35% of the next AED 1 million and 50% of spend from AED 2 million up to the AED 5 million cap, each band with a minimum R&D headcount, so it is worth at most AED 2 million a period. Each project must meet the OECD Frascati Manual definition, be carried out in the UAE, cost at least AED 500,000 and be pre-approved by the Emirates Research and Development Council. The Council's pre-approval portal was reported as not yet open in mid-2026, so we confirm the current position before planning a claim.
No. A refundable credit was discussed during consultation, but the law as enacted gives a non-refundable credit that reduces corporate tax first and then, for large multinational groups, Top-up Tax. Unused credit can be carried forward, subject to conditions. The Ministry of Finance has said a second phase will consider refundability, and some published summaries still show the old consultation design.
It is a written request asking the FTA how it applies the law to your specific facts. The FTA amended its clarification rules from 1 March 2026 and published a new Private Clarifications guide (TPGPC1) in July 2026. A request makes sense when significant sums turn on an unclear point and the facts are settled. It also puts your position before the FTA, so we review the question with you before deciding to file.
Yes. We check the computation and the positions behind it, and set out where we agree and where we would take a different view. If we find an error in a filed return, the route depends on its size: an error over AED 10,000 must be corrected by voluntary disclosure, while a smaller one can be corrected in the next return. The time limit for a disclosure is short, so we raise errors as soon as we find them.
Often needed together
Talk to us
A decision to take before year end?
Tell us what the board is deciding. We will explain what the analysis involves, what we need from your team and how long it usually takes. The first conversation is free.
- FTA Registered Tax Agency
- Tax team with Big Four audit-firm experience
- Mon to Fri, 9:00 am to 6:00 pm (GST)
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