Free zone de minimis test

A Qualifying Free Zone Person may earn a limited amount of non-qualifying revenue without losing the 0% rate. Exceed it, and the status is lost for the current period and the four that follow — with 9% applying to all income, qualifying included.

The de minimis threshold is the lower of 5% of total revenue or AED 5,000,000 (Cabinet Decision No. 100 of 2023, Article 4).

Your figures for the tax period

InputAmount (AED)
Adjusted total revenue, after the exclusions in Cabinet Decision 100/2023
Adjusted non-qualifying revenue, after the same exclusions
Taxable income (for the impact estimate)

Have both figures been adjusted?

The word doing the work above is adjusted. The test is run on revenue with the Article 4 exclusions already taken out of both numbers — and a figure straight from the trial balance is not that. Running the test on unadjusted revenue produces a number that looks like an answer and is not one, which is worse than no number at all.

Confirm each of these before the tool will put a verdict against your figures. If you cannot confirm one, that is the finding: the reconciliation has to happen first.

Revenue attributable to a foreign permanent establishment has been excluded from both figures
Revenue attributable to a domestic permanent establishment has been excluded from both figures
Revenue from immovable property in a free zone has been treated as the decision requires
The two figures are drawn from the same tax period and the same entity

The other conditions

The de minimis test is one of several requirements. Status is lost if any of them fails:

Not certain how your revenue splits?

In practice the difficulty is rarely the arithmetic — it is classifying each revenue stream against the activity lists, and evidencing the classification. Classifying a revenue stream against the activity lists is a tax position, and it is one your adviser signs, not us. What we do afterwards is implement that classification in your data and validation logic, and keep the evidence retrievable.

Email us your breakdown

This material is provided for general information only and does not constitute tax, legal or accounting advice. Requirements and thresholds change; positions depend on individual circumstances. Consult a qualified adviser before acting. Position as at July 2026, based on Federal Decree-Law No. 47 of 2022, Cabinet Decision No. 100 of 2023 and Ministerial Decision No. 229 of 2025.

Sources

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