The UAE Ministry of Finance has issued Ministerial Decision No. 229 of 2025, which refines the scope of Qualifying and Excluded Activities under Federal Decree-Law No. 47 of 2022 on Corporate Tax. Following Ministerial Decision No. 265 of 2023, the new framework provides greater clarity and flexibility for Free Zone companies while at the same time introducing more rigorous compliance requirements.
One major update is the removal of the term “in raw form” for trading of Qualifying Commodities. Companies may now trade metals, minerals, industrial chemicals, energy products, agricultural commodities, and associated by-products, so long as a Quoted Price exists. A Quoted Price is defined as a price specified by a Recognised Commodity Exchange Market or a Recognised Price Reporting Agency.
To further remove any uncertainty, Ministerial Decision No. 230 of 2025 lists 13 Recognised Price Reporting Agencies, ensuring businesses can confidently substantiate pricing when trading commodities. Decision 230 directly supports the implementation of Decision 229 and in doing so, aims to prevent ambiguity around acceptable benchmarks.
In addition, other beneficial amendments include:
- Treasury and financing services may now be provided to Related Parties or for a taxpayer’s own account (self-investment), expanding opportunities for Free Zone companies without jeopardising Qualifying Free Zone Person (QFZP) status.
- Distribution of goods or materials in or from a Designated Zone now expressly includes transactions with public benefit entities, which do not affect the de-minimis threshold.
- Finance and leasing exceptions have been broadened to include trading of Qualifying Commodities, while references for reinsurance and insurance activities have been updated to Federal Decree-Law 48 of 2023.
Together, these reforms expand qualifying activities and modernize legal references, while at the same time introducing a 51% revenue test for commodity traders heavily engaged in distribution or logistics to prevent misuse of Free Zone benefits.
As a result, Free Zone companies should review contracts, transfer pricing policies, and documentation to ensure continued eligibility for the 0% corporate tax rate and compliance with the new pricing rules. The UAE’s competitive Corporate Tax framework, coupled with preferential treatment for Qualifying Activities, ultimately strengthens its position as a global investment hub and supports long-term economic sustainability.
Viewed collectively, the latest ministerial decisions strike a careful balance between expanding opportunities and tightening compliance, ensuring Free Zone companies can continue to benefit from the UAE’s 0% corporate tax regime while reinforcing the country’s standing as a global investment hub.
Get in Touch
For more information on this topic, please contact Suneer Kumar, Head of Corporate Practice on suneer@alsuwaidi.ae and Vida Grace Serrano, Corporate Senior Associate on Vida@alsuwaidi.ae.
Alsuwaidi & Company’s corporate team advises on a wide range of matters including regulatory compliance, investment structuring, M&A, employment, and tax strategy. We support multinational and regional businesses across sectors with practical, commercially grounded legal guidance.