Ministerial Decision No. 229 of 2025 replaced Ministerial Decision No. 265 of 2023 and reset the Qualifying Activities list that decides whether a UAE Free Zone company keeps its 0% corporate tax rate as a Qualifying Free Zone Person.
Key changes:
- Manufacturing is now a standalone Qualifying Activity
- Commodity trading expanded to chemicals, by-products, and environmental commodities (carbon credits, renewable energy certificates)
- The old "recognised exchange" requirement for commodity pricing was removed
- A new anti-abuse guardrail: commodity trading loses Qualifying treatment if 51%+ of revenue comes from distribution, warehousing, logistics, or inventory management
- Applies retroactively from 1 June 2023
Full breakdown of what changed, who newly qualifies, and who should review past filings: https://qasproglobal.com/uae-free-zone-qualifying-activities-2026-ministerial-decision-229/
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