ADGM vs DIFC: which free zone fits you?

Corporate tax: Free Zone regime and Qualifying Free Zone Person (QFZP) · applies to all UAE free zones

Under Federal Decree-Law No. 47 of 2022 a Free Zone Person that meets all conditions to be a Qualifying Free Zone Person (QFZP) pays 0% corporate tax on its Qualifying Income and 9% on its other taxable income. The FTA's Free Zone Persons guide (CTGFZP1, May 2024) lists the conditions: the regime applies to a Free Zone Person (3.2.1); it must maintain adequate substance in a Free Zone (3.2.2); derive Qualifying Income (3.2.3); not have elected to be subject to the standard corporate-tax rules (3.2.4); comply with the arm's-length principle (3.2.5); maintain transfer-pricing documentation (3.2.6); maintain audited financial statements (3.2.7); and its non-qualifying revenue must meet the de minimis requirements (3.2.8). A QFZP that fails any condition, or elects out, ceases to be a QFZP from the beginning of that tax period and for the four subsequent tax periods. The guide states that all taxpayers should check with their respective Free Zone Authority to confirm whether they operate in a Free Zone or Designated Zone for corporate-tax purposes.

1. [1] tax.gov.ae · 2024-05, opened 2026-10-24

Corporate tax: Qualifying Activities, Excluded Activities and de minimis (Ministerial Decision 229/2025) · applies to all UAE free zones

Ministerial Decision No. 229 of 2025 (issued 28 August 2025, effective 1 June 2023, repealing Ministerial Decision 265 of 2023) lists the Qualifying Activities of a QFZP: (a) manufacturing of goods or materials; (b) processing of goods or materials; (c) trading of Qualifying Commodities; (d) holding of shares and other securities for investment purposes; (e) ownership, management and operation of ships; (f) reinsurance services; (g) fund management services; (h) wealth and investment management services; (i) headquarter services to Related Parties; (j) treasury and financing services to Related Parties or for its own account; (k) financing and leasing of aircraft; (l) distribution of goods or materials in or from a Designated Zone; (m) logistics services; (n) activities ancillary to (a)-(m). Excluded Activities are: (a) any transactions with natural persons, except in relation to activities (e), (g), (h) and (k); (b) banking activities; (c) insurance activities (without prejudice to (f) and (i)); (d) finance and leasing activities (without prejudice to (c), (e), (j) and (k)); (e) ownership or exploitation of immovable property, other than Commercial Property in a Free Zone transacted with a Free Zone Person; (f) activities ancillary to those. De minimis: non-qualifying revenue in a tax period must not exceed the lower of 5% of total revenue or AED 5,000,000. A QFZP must also prepare audited financial statements under Ministerial Decision 84 of 2025. Distribution in or from a Designated Zone requires that goods entering the UAE are imported through the Designated Zone and are supplied to a customer who resells, processes or alters them, or to a public benefit entity. Shares are deemed held for investment when held for an uninterrupted 12 months.

1. [1] mof.gov.ae · 2025-08-28, opened 2026-10-24

Corporate tax: the official list of Free Zones (Cabinet Resolution 54/2023) was not available · applies to all UAE free zones

Cabinet Resolution No. 54 of 2023 (dated 30 May 2023) defines the Free Zones for the purposes of the Corporate Tax Law by reference to an attached schedule. The only official copy found (hosted by Dubai Silicon Oasis Authority) contains the two-page body without the schedule, so this research cannot confirm from a primary source which zones are Free Zones for corporate-tax purposes. Zone records therefore publish a zone's own statement, if any, and the FTA's advice to confirm with the Free Zone Authority.

1. [1] dso.ae · 2023-05-30, opened 2026-10-24

Free Zone and Designated Zone definitions for corporate tax, VAT and excise (FTA Public Clarification TAXP010) · applies to all UAE free zones

FTA Public Clarification TAXP010 (October 2026) explains that the definitions of Free Zone and Designated Zone differ between the corporate-tax, excise-tax and VAT laws, and that a business must determine its status under each law separately. A Corporate Tax Free Zone is a designated and defined geographic area within the UAE specified in a Cabinet decision at the suggestion of the Minister. A Corporate Tax Designated Zone is a VAT Designated Zone (listed in Cabinet Decision 59/2017 as amended) that is also a Free Zone under the Corporate Tax Law. A VAT Designated Zone is a Free Zone listed in Cabinet Decision 59/2017 and its amendments that meets the conditions of Article 51(1) of the VAT Executive Regulation. An Excise Tax Designated Zone is a free zone or specified area meeting the conditions of the Excise Tax law and regulation, approved by the FTA. Businesses should confirm with their Free Zone authority whether they are in a Free Zone or Designated Zone for corporate-tax purposes, and may check the FTA's published list for VAT.

1. [1] tax.gov.ae · 2026-10, opened 2026-10-24

VAT Designated Zones: FTA list (Cabinet Decision 59/2017 as amended to Cabinet Decision 81/2021) · applies to listed zones

The FTA's List of Designated Zones for VAT (English section marked an unofficial translation; based on Cabinet Decision 59/2017 effective 1 January 2018 and amending decisions 35/2018, 43/2019, 34/2021, 63/2021 and 81/2021) names: Abu Dhabi - Free Trade Zone of Khalifa Port, Abu Dhabi Airport Free Zone, Khalifa Industrial Zone (all from 01/01/2018), Al Ain International Airport Free Zone and Al Butain International Airport Free Zone (from 18/06/2018). Dubai - Jebel Ali Free Zone (North-South), Dubai Cars and Automotive Zone (DUCAMZ), DAFZA Industrial Park Free Zone - Al Qusais, Dubai Aviation City, Dubai Airport Free Zone (all from 01/01/2018), International Humanitarian City - Jebel Ali (from 18/06/2018), Dubai CommerCity (from 01/01/2021); Dubai Textile City was designated 01/01/2018 to 04/04/2021 and the Free Zone Area in Al Quoz 01/01/2018 to 01/07/2021. Sharjah - Hamriyah Free Zone, Sharjah Airport International Free Zone (01/01/2018). Ajman - Ajman Free Zone (01/01/2018). Umm Al Quwain - Umm Al Quwain Free Trade Zone in Ahmed Bin Rashid Port and on Sheikh Mohammed Bin Zayed Road (01/01/2018). Ras Al Khaimah - RAK Port Free Zone, RAK Maritime City Free Zone (01/01/2018), RAK Airport Free Zone (01/01/2018 to 04/07/2019), Al Hamra, Al Ghail and Al Hulaila Industrial Zone - Free Zone (from 04/07/2019). Fujairah - Fujairah Free Zone, FOIZ (Fujairah Oil Industry Zone) (01/01/2018). This is the latest list found (dated 21 September 2021); zones not on it were not VAT Designated Zones as of that date.

1. [1] tax.gov.ae · 2021-09-21, opened 2026-10-24

Customs treatment and mainland market access for free-zone companies (u.ae) · applies to all UAE free zones

The UAE Government portal (u.ae, page 'Running a business in a free zone', updated 28 September 2026) states that free-zone companies can be fully owned by foreign investors; may import goods from outside the UAE, export and re-export with generally no restrictions as long as goods do not enter the mainland market without customs clearance; pay 0% customs duty on goods imported into the free zone and none on goods stored for re-export, with duty due only when goods move into the mainland market. Access to the mainland market is regulated: to sell goods or services locally, a free-zone company must work through a licensed mainland distributor or establish a mainland branch or company, and direct mainland sales are generally not permitted without the required mainland licences or approvals. The page refers to Federal Decree-Law 32/2021 on Commercial Companies and Dubai Executive Council Resolution 11/2025.

1. [1] u.ae · 2026-09-28, opened 2026-10-24

Dubai: free-zone establishments operating on the mainland (Executive Council Resolution 11/2025) · applies to free zones in the Emirate of Dubai (not DIFC financial establishments)

Executive Council Resolution No. 11 of 2025 (issued 3 March 2025, in force on publication) regulates Dubai free-zone establishments that wish to conduct activities outside their free zone within Dubai. It does not apply to financial establishments licensed in the DIFC. An establishment may do so with one of three DET instruments: a licence to establish a branch within the Emirate; a licence to establish a branch operating out of the free zone (both valid one year, renewable); or a temporary permit of up to six months for specific activities. Conditions include the licensing authority's approval, approvals of the supervising government entities where required, a valid free-zone licence and payment of fees; the establishment must comply with applicable federal and local legislation and keep separate financial records for mainland activities. Existing free-zone-registered workforce may be used. DET fees: AED 10,000 per year for issuing or renewing a licence for a branch operating out of the free zone, and AED 5,000 for issuing or renewing a temporary permit. DET, with the licensing authorities, was to issue within six months a list of activities and the instrument each requires. Establishments already operating on the mainland had one year to comply (extendable once).

1. [1] dso.ae · 2025-03-03, opened 2026-10-24

Media activities in free zones (Federal Decree-Law 55/2023) and National Media Authority permits · applies to media free zones and media activities in any free zone

Federal Decree-Law No. 55 of 2023 Concerning Media Regulation applies to all persons, media establishments and institutions, media outlets and media free zones that practise media activities in the UAE (Article 2). The Competent Authority (the local government body concerned with licensing media activities, or the Council where there is none) issues licences or permits to practise media activities in free zones; the activity must be practised within the free zone's geographical borders, otherwise the laws in force in the country apply; licensees must keep to the activities in their licence and renew on time, and are subject to the Competent Authority's oversight (Article 6). The National Media Authority (nma.gov.ae) publishes federal e-services: a ground filming permit within the country at AED 500 per day (apply 15 working days ahead; 5 working days processing); a permit for an individual to provide advertising or media content on social media, free for three years and then AED 1,000 (3 working days); and issuance of media licences of a commercial nature, whose fee 'depends on the service'.

1. [1] dda.gov.ae · 2023, opened 2026-10-24
2. [2] nma.gov.ae · 2026, opened 2026-10-24
3. [3] nma.gov.ae · 2026, opened 2026-10-24
4. [4] nma.gov.ae · 2026, opened 2026-10-24

Ministry of Economy and Tourism: register of company registrars in free zones · applies to all UAE free zones

The Ministry of Economy and Tourism publishes a page of company registrars in free zones, grouped by emirate licensing authority (page footer date 23 October 2026). It lists, for Abu Dhabi: Masdar, Media Zone Authority - TWOFOUR54, Abu Dhabi Airports Free Zone, KIZAD and Abu Dhabi Global Market. Dubai: the Dubai Development Authority districts (Dubai Internet City, Dubai Production City, Dubai Studio City, Dubai Outsource City, Dubai Science Park, Dubai Design District, Dubai Wholesale City, Dubai Knowledge Park, Dubai Media City, Dubai International Academic City), Dubai International Financial Centre Authority, Dubai Silicon Oasis Authority, Dubai Maritime City Authority, Trakhees, Dubai Healthcare City Authority, Dubai Multi Commodities Centre Authority, Meydan, International City for Humanitarian Services Authority, Dubai South, Dubai World Trade Center Authority, Dubai Airport Free Zone, Commerce City, Jebel Ali Free Zone with Dubai Textile City, Dubai Auto Zone, Dubai Industrial Park and Dubai Gold and Diamond Park. Sharjah: Sharjah International Airport Free Zone, Hamriyah Free Zone Authority, Sharjah Publishing City, Sharjah Research Technology & Innovation Park, Sharjah Media City - Shams. Ajman: Ajman Media City, Ajman Free Zone. Ras Al Khaimah: RAKEZ, Ras AlKhaimah Maritime, Innovation City. Umm Al Quwain: Umm AlQuwain Free Trade Zone. Fujairah: Fujairah Free Zone, Fujairah Creative City. Not on the list as of that date: Ajman NuVentures Centre, Sharjah Healthcare City, Fujairah Oil Industry Zone, IFZA (International Free Zone Authority), Sharjah COMTECH and Dubai Carpet Free Zone. Absence from this register is recorded as a fact, not as a statement that a zone cannot license companies.

1. [1] moet.gov.ae · 2026-10-23, opened 2026-10-24
2. [2] moet.gov.ae · 2026-10-23, opened 2026-10-24