NaqoodFTA Decision 15 of 2026 Resets Corporate Tax Exemption Filing Rules
On 15 September 2026 the Federal Tax Authority’s FTA Decision No. 15 of 2026 on the Provisions of Exemption from Corporate Tax took effect. The decision was issued on 8 September 2026. It replaces FTA Decision No. 7 of 2023 and sets the administrative path for persons who must apply to be exempt from Corporate Tax under Federal Decree-Law No. 47 of 2022 (the Corporate Tax Law).
This is procedure, not a new list of who is exempt. Qualifying Investment Funds, pension and social security funds, and certain wholly owned companies still take their exemption conditions from the Corporate Tax Law and related Cabinet decisions. Decision 15 tells them when and how to apply on EmaraTax after they register for Corporate Tax.
What does FTA Decision No. 15 of 2026 change?
Article 2 requires persons in Article 4(1) paragraphs (e), (f), (g), (h) and (i) of the Corporate Tax Law to apply for Tax Registration within the timelines in FTA Decision No. 3 of 2024. After registration is approved, persons in paragraphs (f), (g), (h) and (i) may apply for exemption if they meet the law’s conditions.
Article 3(1) then moves the ordinary exemption application window. Eligible applicants apply after the Tax Period in which they met the exemption conditions, and no later than 90 Business Days after that period ends. Business Days exclude weekends and federal official holidays. Under the repealed Decision 7 of 2023, the window was 60 business days.
| Who (Art. 3) | Catch-up deadline | What it covers |
|---|---|---|
| UAE juridical person wholly owned and controlled by a government entity or government controlled entity (Art. 3(5), Art. 4(1)(h) owned by (a)/(b)) | 31 October 2026 | Any Tax Period that ended before 1 January 2026, if the exemption conditions were met for that period |
| Person under Art. 4(1)(i) eligible for retrospective exemption under Cabinet Decision No. 55 of 2025 (Art. 3(2)(a)) | 31 December 2026 | Retrospective exemption applications for those Cabinet Decision 55 persons |
| Juridical person entitled under Art. 5 of Cabinet Decision No. 34 of 2025 (Art. 3(3)) | 31 December 2026 | Tax Periods that commenced in calendar year 2025 and end on or before 31 August 2026 |
Article 4 repeals Decision 7 of 2023 from 15 September 2026. Article 5 applies Decision 15 to Tax Periods commencing on or after 1 June 2023, for applications submitted on or after the effective date. The Decision text does not invent AED thresholds; eligibility still turns on the Corporate Tax Law conditions and any Cabinet or Ministerial rules that apply to the category.
Who must apply for Corporate Tax exemption under Decision 15?
Not every Exempt Person uses this application track the same way. Decision 15’s exemption application rules (Article 2(2) and Article 3(1)) focus on:
- Qualifying Investment Funds (Article 4(1)(f))
- Public or qualifying private pension and social security funds (Article 4(1)(g))
- UAE juridical persons wholly owned and controlled by certain Exempt Persons (Article 4(1)(h))
- Other persons the Cabinet designates under Article 4(1)(i), including routes opened by Cabinet Decision No. 55 of 2025 and related instruments
Qualifying Public Benefit Entities (paragraph (e)) still register under Article 2(1), but the exemption application clauses that follow name paragraphs (f) to (i). Government Entities and Government Controlled Entities sit in paragraphs (a) and (b); Decision 15 uses them mainly as owners when a wholly owned company seeks the Article 3(5) catch-up.
Ordinary taxable SMEs that are not in these exempt categories do not use Decision 15 to “opt out” of Corporate Tax. Their path remains registration, return filing, and any relief that applies under the Corporate Tax Law, including the returns track covered in the Corporate Tax with SBR filing guide and the broader Corporate Tax overview.
How do group-owned companies have to file?
Article 3(4) sets a parent-first order. A juridical person in paragraphs (h) or (i) that is wholly owned and controlled by a person in paragraphs (f), (g) or (h) may apply only if the owner has already applied for exemption. The FTA will not decide the subsidiary’s application until it approves the owner’s application.
That matters for fund groups and holding stacks. Sequence the EmaraTax filings so the Qualifying Investment Fund or pension fund (or other controlling Exempt Person) is in first. Then file for each wholly owned company. Do not assume a subsidiary can clear exemption while the owner’s application is still pending.
Article 3(6) says that, once approved, the exemption is generally effective from the start of the Tax Period named in the application. Article 3(7) lets the FTA set a different effective date in listed cases, for example a wrong Tax Period on the registration form, a mid-period acquisition by an exempt owner, supporting evidence that points to the following period, or retrospective Cabinet legislation.
What should UAE finance and fund teams check now?
If you sit in an Article 4(1)(f) to (i) category, confirm Tax Registration is complete under Decision No. 3 of 2024 before you open the exemption form. Diary the 90-Business-Day clock from each Tax Period end, not from the day conditions were first met mid-year.
Treat 31 October 2026 as the near-term catch-up for government-owned UAE companies covering periods that ended before 1 January 2026. Treat 31 December 2026 as the catch-up for Cabinet Decision 55 retrospective cases and for the Cabinet Decision 34 of 2025 Art. 5 periods that began in 2025 and ended on or before 31 August 2026. Keep ownership charts, regulatory approvals, and period-end financials ready so EmaraTax answers match the Decision’s categories.
Naqood is FTA-accredited accounting software for UAE businesses. Clean ledgers and period closes make it easier for fund administrators and tax agents to evidence Tax Periods and ownership when exemption applications sit beside ordinary Corporate Tax compliance.
Useful related reads: How to register for Corporate Tax in the UAE, Corporate Tax with SBR filing, and Corporate Tax. Official text: FTA Decision No. 15 of 2026 (PDF) on tax.gov.ae legislation.
Frequently asked questions about FTA Decision No. 15 of 2026
When does FTA Decision No. 15 of 2026 take effect?
It takes effect on 15 September 2026. It was issued on 8 September 2026 and listed on the FTA legislation portal. From that effective date it repeals FTA Decision No. 7 of 2023.
How long do you have to apply for Corporate Tax exemption?
Under Article 3(1), apply after the end of the Tax Period in which you met the exemption conditions, and no later than 90 Business Days after that Tax Period ends. Catch-up deadlines in Article 3(2), (3) and (5) may apply instead for listed groups.
Does Decision 15 change who is exempt from Corporate Tax?
No. It sets registration and application procedure for the exemption categories that must apply to the FTA. Who qualifies still comes from Article 4 of the Corporate Tax Law and the Cabinet or Ministerial conditions for each category.
What replaced FTA Decision No. 7 of 2023?
FTA Decision No. 15 of 2026. Article 4 repeals Decision 7 from 15 September 2026. Applications submitted on or after that date follow Decision 15, including for Tax Periods that began on or after 1 June 2023.
Are there AED amounts in Decision 15?
No. The Decision text does not prescribe AED thresholds for these exemption applications. Monetary tests, where they exist, sit in other Corporate Tax instruments (for example Small Business Relief), not in Decision 15.
This guide is for general information and does not constitute tax or legal advice. For how the rules apply to your specific situation, consult a qualified UAE tax adviser. Naqood is an FTA-accredited accounting platform for UAE businesses.