The Federal Tax Authority has issued Decision No. 15 of 2026 (issued 8 September 2026, effective 15 September 2026), replacing FTA Decision No. 7 of 2023 as the procedural rulebook for Exempt Persons under the Corporate Tax Law: who must register, who must additionally apply for their exemption, by when, and from what date an approved exemption takes effect. The headline improvements – a longer 90-Business-Day application window and a set of pragmatic effective-date fixes – come packaged with three hard retrospective deadlines, the earliest of which, 31 October 2026, is only weeks away and aimed at government-owned subsidiaries seeking exemption for pre-2026 periods.
Effective date and scope: The Decision took effect on 15 September 2026 and applies to Tax Periods commencing on or after 1 June 2023 – i.e., the whole Corporate Tax era – but only for applications submitted on or after the effective date (Article 5). Applications already lodged under the old Decision No. 7 of 2023 are unaffected; everything filed from 15 September follows the new rules, and Decision 7/2023 is repealed (Article 4).
The statutory frame: Articles 4 and 51 of the Corporate Tax Law
The Decision is procedural machinery bolted onto two provisions of the Corporate Tax Law, and it cannot be read without them.
Article 4(1) – the Exempt Persons catalogue. The Law exempts nine categories:
| Para | Exempt Person category (Article 4(1), Corporate Tax Law) | Route to exemption |
|---|---|---|
| (a) | Government Entity | Automatic – no registration or application |
| (b) | Government Controlled Entity | Automatic – no registration or application |
| (c) | Person engaged in an Extractive Business (Article 7 conditions) | Notification to the Ministry – outside this Decision |
| (d) | Person engaged in a Non-Extractive Natural Resource Business (Article 8 conditions) | Notification to the Ministry – outside this Decision |
| (e) | Qualifying Public Benefit Entity listed under Cabinet Decision No. 37 of 2023 (Article 9) | Register – exemption flows from the Cabinet listing itself; no separate application |
| (f) | Qualifying Investment Fund meeting the Article 10 conditions (Cabinet Decisions 81/2023 and 34/2025) | Register and apply |
| (g) | Public or private pension / social security fund meeting the prescribed conditions (Ministerial Decision 115/2023) | Register and apply |
| (h) | UAE juridical person wholly owned and controlled by an Exempt Person under (a), (b), (f) or (g) – undertaking the owner’s activity, exclusively holding assets or investing funds for its benefit, or carrying on ancillary activities | Register and apply |
| (i) | Any other Person determined by Cabinet decision – currently including Cabinet Decision No. 55 of 2025 persons and the sports entities under Cabinet Decision No. 1 of 2026 | Register and apply |
Article 51 – Tax Registration. Clause 1 obliges every Taxable Person to register for Corporate Tax and obtain a TRN. Clause 2 extends the Authority’s reach into the exempt population: it empowers the FTA to require Exempt Persons to register in the form, manner, and timeline it prescribes. Decision No. 15 of 2026 is precisely that prescription – Article 2(1) of the Decision invokes “Clause 2 of Article 51” to require registration from the categories in paragraphs (e), (f), (g), (h) and (i) of Article 4(1).
The architecture that emerges: categories (a) and (b) are exempt with no procedural steps; (c) and (d) notify the Ministry of Finance under their own regimes; (e) must register but need not apply (its exemption is conferred by the Cabinet listing); and (f) through (i) must both register and then apply to the FTA, proving their conditions. Registration is never the exemption – it is the doorway to it.
What the Decision prescribes
Step one – registration (Article 2). Persons in categories (e)–(i) submit a Tax Registration application within the timelines of FTA Decision No. 3 of 2024 (the general CT registration-timeline decision), as amended. Only once the FTA approves registration may persons in categories (f)–(i) submit the exemption application – and only where the relevant statutory conditions (Article 10 for funds, MD 115/2023 for pension funds, the ownership-and-activity tests for (h) entities, the relevant Cabinet decision for (i) persons) are actually met.
Step two – the exemption application window (Article 3(1)). The application is made after the end of the Tax Period in which the conditions were met, and no later than ninety (90) Business Days from the end of that Tax Period. Two points: the window is defined in Business Days – any day except Federal Government weekends and official holidays (Article 1) – so a calendar-year entity’s window for FY2026 runs well into May 2027, materially longer than the sixty Business Days the repealed Decision 7/2023 allowed; and the trigger is the period in which conditions were met, not the period in which the entity got around to noticing.
The retrospective carve-outs (Article 3(2)–(3) and 3(5)) – the hard dates:
| Who | Deadline |
|---|---|
| Category (i) persons under Cabinet Decision No. 55 of 2025, applying with retrospective effect | 31 December 2026 |
| Category (i) persons under Cabinet decisions issued on or after 1 January 2026 (e.g., sports entities under Cabinet Decision No. 1 of 2026) | 90 Business Days from the end of the Tax Period in which the relevant Cabinet decision was issued |
| Juridical persons entitled under Article 5 of Cabinet Decision No. 34 of 2025 (QIF/QLP framework), for Tax Periods commencing in calendar 2025 and ending on or before 31 August 2026 | 31 December 2026 |
| Category (h) entities wholly owned and controlled by Government Entities or Government Controlled Entities (Article 4(1)(a)/(b)), for Tax Periods that ended before 1 January 2026 | 31 October 2026 |
The last row (Article 3(5)) is the one that should be circled in red: sovereign-owned SPVs, asset-holding companies, and ancillary-activity subsidiaries of government entities that want exemption for their 2023–2025 periods have until the end of next month. Miss it, and those periods fall back into the ordinary taxable net.
The parent-first sequencing rule (Article 3(4)). An (h) or (i) entity wholly owned and controlled by an (f), (g) or (h) person may apply only where its owner has itself applied – and the FTA will make no decision on the subsidiary’s application until the owner’s is approved. Fund structures should therefore sequence filings top-down: the Qualifying Investment Fund first, its wholly-owned holding and asset SPVs after – and build the parent’s approval time into the subsidiaries’ deadline management, since the 90-Business-Day clocks do not pause for the queue.
When the exemption takes effect (Article 3(6)–(7))
The default is generous: an approved exemption is effective from the start of the Tax Period specified in the application – full-period relief, not relief from approval date. Article 3(7) then gives the FTA a calibrated discretion to substitute a different date in listed (and “other similar”) scenarios: where the Tax Period stated in the registration form was wrong, the exemption runs from the correct period; where the applicant was acquired mid-period by exempt owners under (a), (b), (f) or (g), the FTA sets a date ensuring exemption starts from the first Tax Period commencing after all conditions were satisfied – mid-year acquisitions do not retro-cleanse the pre-acquisition months; where the application named the wrong period but the evidence shows conditions met in the following period, the exemption starts there; where the underlying legislation is retrospective, the exemption reaches back to the period in which conditions were met; and any further instances a Cabinet decision under paragraph (i) may specify. The theme is condition-alignment: the FTA will fix clerical errors in the taxpayer’s favour, but will not let an exemption cover a stretch of a period during which the conditions did not yet hold.
Worked example – a fund structure against the clock
Facts. Meridian Capital Fund (a UAE investment fund, calendar-year) satisfied the Qualifying Investment Fund conditions throughout its Tax Period commencing 1 January 2025 and ending 31 December 2025. It wholly owns MC Holdings Ltd, a UAE SPV holding the fund’s real estate, which meets the Article 4(1)(h) tests for the same period. Separately, Falcon Sports Club qualifies under Cabinet Decision No. 1 of 2026 (issued during 2026), and Gulf Development Co. is wholly owned by a Government Entity and met the (h) conditions for its 2024 and 2025 periods.
Meridian (QIF, FY2025): its 2025 period commenced during calendar 2025 and ended 31 December 2025 – on or before 31 August 2026 – so the Article 3(3) carve-out applies: application due by 31 December 2026 (rather than a 90-Business-Day window that would already have closed). Register first if not yet registered, then apply.
MC Holdings (the (h) subsidiary): it may apply only after Meridian has applied, and its application will sit undecided until Meridian’s is approved (Article 3(4)). File both before year-end, parent first.
Falcon Sports Club (category (i), Cabinet Decision issued in 2026): its deadline is 90 Business Days from the end of the Tax Period in which Cabinet Decision No. 1 of 2026 was issued – for a calendar-year club, 90 Business Days from 31 December 2026, landing in early May 2027.
Gulf Development Co. (government-owned (h), pre-2026 periods): for its 2024 and 2025 Tax Periods, the Article 3(5) deadline is 31 October 2026 – the most urgent date in the Decision, and the file to open this week.
Observations
The repeal-and-replace is cleaner than it looks. Decision 7/2023’s sixty-Business-Day window was widely criticised as tight for entities that needed audited numbers to evidence their conditions; ninety Business Days is a genuine concession. But the new Decision applies only to applications filed from 15 September 2026 – an entity whose old-regime window has already lapsed does not get a revival, except through the express retrospective carve-outs.
Category (e) is register-only. Qualifying Public Benefit Entities register (their listing in Cabinet Decision 37/2023 is the exemption) but file no application – a distinction boards of charities and foundations routinely miss in both directions: some skip registration entirely, others file unnecessary exemption applications.
Conditions are annual, applications are not. The application is a gateway event, but the underlying conditions – Article 10 for funds, ownership-and-activity for (h) entities – must be met continuously. An approved exemption does not immunise later periods in which conditions lapse; monitoring belongs in the annual compliance calendar alongside the registration the entity retains.
The acquisition rule rewards planning. Article 3(7)(b) means a company acquired mid-period by an exempt owner is taxable for that straddling period and exempt only from the next. Where feasible, aligning completion with the start of a Tax Period preserves a full year of exemption – a small structuring point with a nine-percent consequence.
What affected entities should do now
Between now and 31 October 2026: government groups should sweep their subsidiary registers for (h)-eligible entities with pre-2026 periods and file immediately. Before 31 December 2026: Cabinet Decision 55/2025 persons and 2025-period QIF/QLP structures should register (if not already) and apply, sequencing parent-then-subsidiary in fund structures. On an ongoing basis: diarise the 90-Business-Day window from each Tax Period end; keep condition-evidence (ownership charts, activity descriptions, regulatory oversight confirmations, fund condition testing) contemporaneous; and verify the Tax Period stated in the registration form, since Article 3(7)(a) shows the FTA treats it as the anchor for the exemption’s effective date.
How TSAC can help
TSAC advises exempt-category entities – investment funds and their SPVs, pension funds, public benefit entities, government-owned subsidiaries, and Cabinet-designated persons – on registration, exemption applications, condition testing, and structuring around the effective-date rules. Three deadlines in this Decision expire within months of its issuance; the entities that treat 15 September as the starting gun, rather than the announcement, will be the ones that keep their exemptions for the periods that matter.