Boru Consulting

The 0% UAE Corporate Tax Rate Is Built on QFZP Status

A Free Zone licence, however, is only the starting point.
Under the UAE Corporate Tax regime, the 0% rate applies only where a company qualifies as a Qualifying Free Zone Person and continues to satisfy a series of legislative conditions throughout each tax period.
The rules go well beyond incorporation. They distinguish between Qualifying Income and non-qualifying income, define specific Excluded Activities, and apply a limited de minimis threshold.
The consequences of getting that analysis wrong can extend far beyond a single transaction.

In our latest article, we examine how the QFZP regime operates, what determines whether income qualifies for the 0% rate, and why ongoing compliance is just as important as choosing the right Free Zone.

You build the vision.
We handle the noise.

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UAE eInvoicing: the 30 October 2026 deadline

Phase 1 entities with annual revenue above AED 50 million must appoint an ASP by 30 October 2026. The 1 January 2027 go-live has not moved.

That leaves just nine weeks for ASP selection, ERP integration, data cleanup, and testing.

Read the full article on our blog — link in bio.

Pillar Two UAE DMTT: the 15% floor under UAE tax

The UAE’s Domestic Minimum Top-up Tax is not a separate tax. It applies a 15% minimum floor to in-scope multinational groups from 1 January 2025.

If your UAE structure is within scope, the real question is not just corporate tax — it is how the DMTT changes the final outcome.

Read the full article on our blog via the link in bio.

The Pre-Exit Year for UK-to-UAE HNWI

The pre-exit year is not a checklist — it's an architecture engineered backwards from your SRT exit date.

TRF designation, CGT rebasing, the long-term resident IHT tail, UAE 90-day residence, Golden Visa, CMC reconstitution, QFZP substance, and DIFC will all need to be positioned around that single date.

The architecture takes 12 months, not 3-4. Split-year cases need a locked fact pattern. TRF needs a strategy across three years. UAE substance needs 90-180 days. Banking, family relocation, and UK property sales each add months.

Five traps cause most failed exits: vague timing without locked split-year case; delaying TRF to 2027/28 (300bps tax uplift); building UAE substance too late; selling UK property with UK residence still active at midnight; spouse/children staying UK-resident as "school anchors."

Post-exit year one tests the architecture. TRF is filed, rebasing elections made, LTR IHT tail begins, UAE residency is operational, substance file grows quarterly.

Full article on our website — link in profile.

DIFC and ADJD Wills for UK HNWIs After April 2025

Since 2023, non-Muslim UAE residents have a federal civil framework for wills (Federal Decree-Law No. 41 of 2022). There are two main registration routes: DIFC in Dubai and the Abu Dhabi Civil Family Court.

DIFC Wills are common-law style in English. A Full Will can cover worldwide assets. Guardianship is valid only for minors in Dubai or Ras Al Khaimah. Probate is handled by DIFC Courts, usually within weeks.

Abu Dhabi Wills operate under a civil-law system in Arabic and English. Typically lower-cost, they cover Abu Dhabi assets primarily, with federal reach. Over 21,000 civil wills were registered from 2022 to the end of 2025.

Important: A UAE will does not eliminate UK Long-Term Resident IHT on worldwide assets. It does not affect UK SRT exit, does not create UAE tax residency, and does not replace a UK will for UK-situs assets. Two coordinated wills are usually the best architecture.

Without a registered will, the default is 50% to the spouse and 50% equally among children, without gender distinction.

For UK HNWIs, the will is the succession instrument, not the full architecture. It must be coordinated with UK IHT planning, a UK will, and UAE tax residency.

Full article on our website — link in our profile.

The UK Statutory Residence Test: It's About More Than 183 Days

Many still believe that spending fewer than 183 days in the UK means you're not UK tax resident. That's not true.

The 183-day rule is only one part of the Statutory Residence Test. Your residence can also depend on previous UK residence, accommodation ties, family connections, work days, and how your days are counted.

Common mistakes:
A UK property kept for visits creates an accommodation tie. More than three hours of work in the UK counts as a work-day. Spending over 90 days in the UK in either of the previous two years creates a 90-day tie.

For HNWIs and mobile families, these details matter. Your residence affects income tax, capital gains tax, inheritance tax, and cross-border structures.

The key point: UK tax residence is determined by the Statutory Residence Test and documented facts, not by intention.

At Boru Consulting, we help internationally mobile founders and private clients understand how the SRT applies to their circumstances and plan cross-border movement with confidence.

If you'd like to review your residence position, contact us through our page or send a direct message.

You build the vision. We handle the noise.

Understanding the UAE Golden Visa: Benefits and Limitations

The UAE Golden Visa grants the right to reside in the UAE, but it is essential to note that it does not confer UAE tax residency.

Key benefits of the UAE Golden Visa include:
- A long-term permit (5 or 10 years, renewable),
- No requirement for a UAE national sponsor,
- Freedom to work, study, and sponsor family members,
- Exemption from the 6-month absence rule.

It is crucial to understand that the UAE Golden Visa does not imply UAE tax residence, which requires 90 days + residence permit + permanent place of residence/business, or 183 days of presence.

For those seeking the Golden Visa through property investment, a minimum of AED 2 million based on current DLD valuation is required, and mortgaged and off-plan properties are eligible.

The employment route, however, has been paused since October 2025, with zero approvals in Q2 2026, making the property route the most reliable option.

Read the full article in our Insights blog to learn more — link in our profile.

A UAE Free Zone licence does not automatically mean 0% Corporate Tax.

Many businesses assume that setting up in a UAE Free Zone guarantees the 0% rate.

It doesn't.

To qualify, a company must meet five conditions every tax period to be recognised as a Qualifying Free Zone Person (QFZP).

Here's what every business owner should know:
✔ Meet all five QFZP conditions every year.
✔ Earn Qualifying Income only.
✔ Keep non-qualifying income below the lower of 5% of total revenue or AED 5 million.
✔ Maintain adequate economic substance in the UAE.
✔ Apply transfer pricing correctly and keep supporting documentation.

One mistake can be costly.

If a company fails just one of the QFZP conditions or exceeds the de minimis threshold:
• The 9% Corporate Tax rate applies to all Taxable Income, not just the non-qualifying income.
• The company loses QFZP status for the current tax period and the following four tax periods.

Understanding these rules before they become a problem is essential for protecting the 0% rate.

Read the full article in our Insights section via the link in our bio.

Family Investment Company vs Trust for the UK HNWI: architectures that survived 2025

A Family Investment Company (FIC) is not a trust replacement. It is a different architecture for a different problem.

After Finance Act 2025 and 2026, both instruments are taxed at full UK rates. The question is now which functions each serves, not which one is "better".

Key difference
- A trust gives fiduciary control through independent trustees and discretionary distribution.
- A FIC gives corporate control through voting shares, bespoke Articles, and a board.

Tax reality
A FIC investing mainly in financial assets pays 25% Corporation Tax on profits.
Dividends extracted by shareholders face a second-layer dividend tax up to 39.35%.
Combined, extracted returns can exceed 50%.
Trusts face income and gain attribution to the settlor, plus IHT charges.

Read the full article in our Insights blog on our website — link in our profile.

UAE Individual Tax Residency: the 90-day rule, the 183-day rule, and the treaty gap

UAE individual tax residency has three alternative tests:
- centre of financial and personal interests in the UAE,
- 183 days of physical presence in any rolling 12-month period,
- 90 days of presence with residence permit + employment/business + permanent place of residence.
The 90-day route is the most useful for internationally mobile HNWIs and the most misunderstood.

The treaty gap
Domestic UAE tax residency does not automatically deliver a Tax Residency Certificate (TRC) for treaty purposes.
For treaty-purpose TRCs, the FTA requires 183 days of physical presence, even if domestic residency is established at 90 days.

Golden Visa ≠ tax residency

Holding a UAE residence visa, including the Golden Visa, does not by itself establish UAE tax residency.
The visa is a precondition for the 90-day route only, not a full substitute for the other conditions.

Read the full article in our Insights blog on our website — link in our profile.