UAE corporate tax: EmaraTax registration

The Corporate Tax (CT) regime applies in the UAE for financial years beginning on or after 1 June 2023. In 2025, registering on EmaraTax is essential for resident entities (onshore and Free Zones) and, in some cases, for foreign persons with a Permanent Establishment (PE) or UAE source income. This article reflects widely adopted UAE best practice and provides a pragmatic roadmap—who must register, how and when to do it, what to file, and where substance, Free Zone and transfer pricing issues typically arise.

Who needs to register?

Registration generally covers:

• Resident juridical persons incorporated in the UAE (onshore);
• Free Zone entities (with special treatment where a Qualifying Free Zone Person is maintained);
• Nonresidents with a UAE PE or certain taxable UAEsource income;
• Tax groups, where eligible and elected.

Exempt persons (e.g., certain public entities and qualifying funds) typically require an application and administrative confirmation of their status.

Free Zones and QFZP status

A Free Zone entity may qualify as a QFZP if it meets stringent conditions:

• Economic substance (people, premises, operating expenditure) in the UAE;
• diligent mapping of qualifying vs non qualifying income;
• full CT compliance (filings, records, transfer pricing).

Failure to meet these conditions can result in standard CT treatment.

Registration windows and timing

Authorities have set staggered deadlines by incorporation date and financial year. Best practice:

• check your window on EmaraTax;
• file well ahead of deadlines to avoid penalties and service impacts;
• promptly update changes (address, officers, ownership).

EmaraTax

1. Create an account / sign in (UAE PASS / responsible person KYC).
2. Complete the CT form: legal details, licence number, financial year start, activities.
3. Upload supporting docs: licences, constitutional docs/resolution, officer IDs, structure chart, bank details.
4. Submit and track the application; respond to RFIs where needed.
5. Enable your CT taxpayer account once the registration number is issued.

Documents and prechecks

• Current trade licences (all relevant jurisdictions).
• Constitution: articles, resolutions, officer registers, ownership structure.
• Official bank and contact details.
• Related party map (transactions, management fees, finance, IP).

Tax base and governance

CT applies to taxable income (operating, financial, gains) after required adjustments (exclusions, deductions, loss rules). Put in place:

• a document framework (contracts, policies, intercompany agreements);
• a reliable closing process (reconciliations, provisions, journals);
• analytics by source (onshore, Free Zone, foreign) and stream.

Transfer pricing: arm’slength standard

Related party dealings (goods, services, royalties, loans/cashpooling) must meet the arm’slength test. Depending on profile and thresholds, master and local files may be expected. Essentials: executed intercompany agreements, comparables, service benefit evidence and objective allocation keys.

Penalties and audit

Administrative penalties apply for non–registration, late registration, late filing/payment and audit noncooperation. Protect yourself with timely filings, robust books and internal controls (review, approval, retention).

Operational checklist

1. Classify the entity: resident, Free Zone (QFZP?), nonresident with PE.
2. Gather core documents (licences, constitutional docs, structure chart, KYC).
3. Plan your EmaraTax submission within the correct window.
4. Establish CT governance (closing, records, policies).
5. Start the TP review (sensitive flows, benchmarks, agreements).

In 2025, successful Corporate Tax Registration in the UAE means anticipating EmaraTax windows, evidencing substance (especially in Free Zones) and securing intragroup flows. Solid CT governance reduces penalties and gives finance teams predictability.

Our lawyers, who are experts in tax law, are available to answer all your questions and provide advice. We offer face-to-face meetings or videoconferencing. You can make an appointment directly online at https://www.agn-avocats.fr/.

AGN AVOCATS – Tax Law
contact@agn-avocats.fr
09 72 34 24 72