UAE replaces its corporate tax exemption application decision

The Federal Tax Authority has extended the exemption application window for certain categories of taxpayer to 90 Business Days and introduced retrospective exemption application routes, with key deadlines falling in October and December 2026.

The UAE Federal Tax Authority (FTA) has issued Decision No. 15 of 2026 (the 2026 Decision) on the Provisions of Exemption from Corporate Tax (CT) (issued 8 September 2026, effective 15 September 2026), which repeals and replaces FTA Decision No. 7 of 2023 (the 2023 Decision). The 2026 Decision applies to Tax Periods from 1 June 2023 for applications filed on or after 15 September 2026.

Scope. The 2026 Decision applies to Persons within paragraphs (e) to (i) of Article 4(1) of the CT Law – Qualifying Public Benefit Entities, Qualifying Investment Funds, Qualifying Limited Partnerships, public and private pension and social security funds, their wholly-owned and controlled subsidiaries, and Cabinet-designated Persons (In Scope Entities). It does not affect Government Entities or extractive businesses, which are exempt by operation of law without application.

The default process remains unchanged, i.e.:

• In Scope Entities must first register for CT; then
• In Scope Entities (save for Qualifying Public Benefit Entities) must apply for exemption within 90 days following the end of the Tax Period in which the relevant conditions were met, with FTA discretion over the effective date.

However, the 2026 Decision acknowledges the evolving nature of UAE tax legislation, and introduces several changes of practical significance.

Exemption application deadline extended from 60 to 90 Business Days. The 2023 Decision required applications to be made within 60 Business Days of the relevant Tax Period end. The 2026 Decision allows 90 Business Days and
clarifies that the application must be made after the Tax Period ends. "Business Day" is also defined for the first time, expressly excluding weekends and official Federal Government holidays (previously undefined).

Registration timelines now cross-refer to the 2024 Decision. The fixed dates in the 2023 Decision are replaced by cross-referencing FTA Decision No. 3 of 2024 (concerning registrations for CT purposes), as amended, aligning exempt-person registration with the general CT registration regime.

Retrospective exemption application (applicable for specific cases only) – two relevant deadlines arise this year for retrospective exemption applications. The 2023 Decision did not allow any flexibility for persons whose status or registration deadlines may have changed due to changes in applicable CT regulations, which are released from time to time. The 2026 Decision acknowledges that CT law and regulations are evolving and has introduced three additional extended application deadlines, which may apply in specific circumstances:

• 31 October 2026:

  • UAE entities meeting the requirements for exemption as entities that are wholly owned and controlled by a Government Entity or Government Controlled Entity (under Article 4.1.h) may claim exemption for Tax Periods ended before 1 January 2026 if they apply by 31 October 2026.

• 31 December 2026:

  • Entities that are exempt pursuant to Cabinet Decision No. 55 of 2025 (foreign entities otherwise meeting the requirements for exemption under Article 4.1.h - i.e. that they are wholly owned and controlled by an Exempt Person that is a Government Entity, Government Controlled Entity, Qualifying Investment Fund or public / private pension and social security fund and that they meet other relevant conditions) are eligible to apply for exemption with retrospective effect, provided they apply by 31 December 2026.
  • Qualifying Limited Partnerships (QLPs) are eligible to apply for exemption (pursuant to the provisions of Cabinet Decision No. 34 of 2025) in respect of Tax Periods commencing during calendar year 2025 and ending on or before 31 August 2026 (i.e. for businesses with a FY ending 31 December this would mean in relation to FY25) by 31 December 2026.

• 90 Business Days from the end of the Tax Period in which a new Cabinet Decision is issued (if issued on or after 1 January 2026): should a new Cabinet Decision be issued on or after 1 January 2026 such that it changes the status of an entity, making that entity eligible for exemption, the entity may apply for exemption with retrospective effect, provided they apply within 90 Business Days following the end of the Tax Period during which the relevant decision is issued.

New parent-first sequencing requirement. A newly introduced rule provides that a wholly-owned subsidiary's application cannot be decided until the FTA has approved the parent's application, so group filings must be sequenced and diarised together.

Annual declaration power not carried over. The reference to the FTA’s power to require exempt persons to file an annual declaration confirming continued eligibility does not appear in the 2026 Decision. This is likely due to consolidation of this requirement into the Tax Procedures framework rather than removing the need to provide such ongoing confirmations.