Ministry of Finance Issues Two Ministerial Decisions on Qualifying Activities and Excluded Activities in Free Zones for Corporate Tax Purposes and on Recognised Price Reporting Agencies 03 September 2025 The Ministry of Finance (MoF) announced the repeal of Ministerial Decision (MD) No. 265 of 2023, replacing it with Ministerial Decision No. (229) of 2025 on Qualifying Activities and Excluded Activities, which clarifies the scope of Qualifying Activities for Corporate Tax purposes in Free Zones. The updates expand the scope of Qualifying Commodity Trading to include industrial chemicals, Associated By-products of Qualifying Commodities, and environmental commodities and provide clarifications on Treasury and financing services for Related Parties. In addition, the MoF has issued Ministerial Decision No. (230) of 2025 on the Specification of Recognised Price Reporting Agencies for the purposes of Ministerial Decision No. (229) of 2025 on Qualifying Activities and Excluded Activities. The Ministry emphasised the pivotal role of Free Zones in driving the UAE’s economic growth, attracting investment, and providing an enabling business environment. It explained that these new decisions reflect the importance of Free Zones and their role in the country’s economic diversification strategy, as well as the UAE’s commitment to providing a supportive business environment in alignment with international tax standards. Updates Ministerial Decision No. (229) of 2025 on Qualifying Activities and Excluded Activities clarifies the scope of the trading of Qualifying Commodities by removing the term “in raw form” and instead allowing the trading of metals, minerals, industrial chemicals, energy and agricultural commodities and Associated By-products, provided that a Quoted Price for such commodities exists. A Quoted Price is a price of the Qualifying Commodity or a Related Commodity specified by a Recognised Commodity Exchange Market or a Recognised Price Reporting Agency specified by a decision issued by the Minister. Ministerial Decision No. (230) of 2025 on the Specification of Recognised Price Reporting Agencies lists the recognised pricing agencies, thereby providing certainty and clarity to taxpayers. Other beneficial changes include the activity of self-investment for the Qualifying Activity of Treasury and financing services to Related Parties or for the taxpayers’ own account, and clarity that the Distribution of goods or materials in or from a Designated Zone allows for transactions with public benefit entities without impacting the de-minimis threshold. The UAE’s competitive Corporate Tax regime, coupled with preferential tax treatment for Qualifying Activities, further strengthens the country’s position as a leading global hub for business and investment and supports the achievement of its sustainable development agenda. All Cabinet Decisions and MDs relating to the Corporate Tax Law are available on the Ministry of Finance’s website
