Dubai Mainland (DED-DXB)Free zone tax status and compliance
Free zone
The Verdict
The Apex of Jurisdictional Legitimacy; Permanent Establishment Anchor.
I. Statutory Basis
As a Qualifying Free Zone Person, this jurisdiction requires strict adherence toCore Income-Generating Activities.UAE Federal Decree-Law No. 47 of 2022. Mainland entities are subject to the standard 9% rate on taxable income exceeding AED 375,000, serving as the definitive defense against global anti-avoidance (Pillar Two) scrutiny.
Compliance Roadmap
Article 34 Transfer Pricing Benchmarking for all intra-group service flows
Full Corporate Tax Registration and 9% Pillar Two alignment for large groups
MOHRE Labor Linkage: Ensuring headcount matches reported Core Income-Generating Activities (CIGA)
Audit Hotspots
Misclassifying Free Zone branch profits as Mainland income to avoid 9% CT
Failing to maintain contemporaneous TP documentation for management recharges
Inadequate substance proof during FTA unannounced physical inspections
Jurisdictional Connectivity
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