ضريبة الشركات الإماراتية — من هيكلة الشخص المؤهَّل في المنطقة الحرة إلى الدفاع في تدقيقات FTA.

All UAE juridical persons (mainland + free zone), foreign branches, natural persons with business turnover above AED 1m, and non-residents with a UAE PE or UAE-source/property nexus. 9% standard above AED 375k; 15% DMTT for in-scope MNEs from 2025.

QFZP = Free Zone Person meeting all six conditions in Cabinet Decision 100/2023: substance, Qualifying Income, no 9% election, de minimis (lower of 5% of revenue or AED 5m), audited FS, TP compliance. 0% on Qualifying Income, 9% on non-Qualifying. Loss of status = 5-year disqualification.

Any time within five years (15 if evasion). Triggers: filing inconsistencies, QFZP de minimis stress, large related-party transactions, restructurings, large carry-forward losses, risk-based selection. First 30 days shape the trajectory.

OECD-style three-tier: Local File + Master File for revenue above AED 200m or MNE Group above AED 3.15b; CbCR for MNE Groups above AED 3.15b. FTA can request from any taxpayer within 30 days. Connected Person transactions must be arm's length.

UAE DMTT effective from financial years starting 1 January 2025. UAE constituent entities of MNE Groups above EUR 750m consolidated revenue pay 15% effective on UAE-sourced GloBE Income. SBIE provides substance relief. QFZP 0% interaction is the biggest planning point.

Required within 20 business days of becoming aware of an error. Reduced penalties (1%/month capped) vs FTA-discovered errors (40% of unpaid tax + fixed). Scoping, timing relative to any pending audit, and multi-tax sequencing are critical.

Reconsideration (40 business days) → TDRC (40 business days) → Federal Court CFI (60 days) → Court of Appeal → Cassation. Grounds-of-challenge framing at Reconsideration largely locks the entire appeal.