UAE free-zone holding company tax support
Holding structures in UAE free zones face a specific mix: qualifying-income classification for QFZP, substance evidence, audited accounts, UBO maintenance and intercompany finance. Here is how we review a holding entity ahead of its first Corporate Tax return.
What a holding assessment covers
Income map
Classify dividend income, capital gains, interest, management-fee recoveries and rental income by source. Each has a different CT treatment.
QFZP conditions
Holding of shares and related ancillary activities can be qualifying under the current decision, subject to specific conditions. Confirm against MD 229/2025 for the activity list.
Substance and audited accounts
Even a holding entity needs substance appropriate to its activity — board decisions in the UAE, qualified directors, audited financial statements for the period.
Related-party finance
Intercompany loans, guarantees and cash pooling must be at arm's length. Interest-deduction rules apply and documentation should be proportionate.
UBO
Beneficial-owner register and declaration remain obligations for the holding entity. ESR reporting is historical only for FYs ending after 31 Dec 2022.
DMTT flag
If the group's consolidated revenue meets the 15% Domestic Minimum Top-up Tax trigger, the holding entity may be in scope. This is a specialist referral rather than something a holding-tax package handles.
Frequently asked questions
Does holding shares guarantee 0% CT?
No. The 0% QFZP rate applies to qualifying income only, and only where every QFZP condition is met. Holding entities can qualify under specific activity lists, but a free-zone licence alone is not enough.
Do we need audited accounts?
A QFZP must prepare audited financial statements for the relevant tax period, prepared in accordance with IFRS. Appoint an auditor before year-end if you are relying on QFZP status.
Are intercompany loans relevant?
Yes. Interest should be at arm's length and the CT interest-deduction rules may limit the deduction at the borrower level. Documentation should match the complexity of the arrangement.
Is ESR still an annual requirement?
No. ESR reporting ended for FYs ending after 31 December 2022. Prior-period obligations remain. See the ESR historical page.
Request holding-structure assessment
Share your structure chart, revenue streams and latest financial statements. We send a scoped QFZP assessment and CT review.
Request assessment