If your UAE entity is exempt from corporate tax, the paperwork behind that exemption changed on 15 September. The Federal Tax Authority issued Decision No. 15 of 2026 a week earlier, repealing the rulebook that had governed exemption applications since 2023. Most of the change is procedural. Two parts are fixed calendar deadlines, and the first falls on 31 October 2026.
TL;DR: FTA Decision 15 of 2026 took effect on 15 September and replaced the old exemption rulebook. Qualifying investment funds, pension funds and exempt-owned subsidiaries must register for corporate tax first, then apply within 90 business days of their tax period end. Two fixed deadlines apply: 31 October and 31 December 2026.
What Changed on 15 September 2026?
The FTA repealed Decision No. 7 of 2023 and replaced it with Decision No. 15 of 2026, issued on 8 September and effective from 15 September (Federal Tax Authority, 2026).
The new decision does not create or remove any exemption. It governs how you claim one: the order of registration and application, how long you have to apply, and which tax period your exemption starts from. It applies to tax periods commencing on or after 1 June 2023, but only to applications submitted on or after 15 September 2026. An application already with the FTA before that date runs under the old rules.
The practical shift is timing. Decision 7 of 2023 was vague on the outer limit for applying. Decision 15 sets a hard 90-business-day window, plus three carve-outs with fixed dates attached.
Do You Actually Need to Apply for Exemption?
Not every exempt person applies. The decision splits Article 4 of the Corporate Tax Law into two groups, and the difference matters.
Entities in paragraphs (e) through (i) of Article 4(1) all have to register for corporate tax. That covers qualifying public benefit entities, qualifying investment funds, public and private pension and social security funds, UAE juridical persons wholly owned by an exempt person, and anyone exempted by a specific Cabinet decision.
Only paragraphs (f) to (i) then submit an exemption application. Qualifying public benefit entities sit outside that list. Their status comes from being named in the schedule to Cabinet Decision No. 37 of 2023, so a charity or foundation on that list registers and files an annual declaration without ever lodging an exemption form.
In our experience this is where the confusion starts. Clients hear "exempt" and assume nothing is due. Registration is still mandatory, and the annual declaration still has to be filed.
When Is the Deadline to Apply?
You apply after the end of the tax period in which you met the exemption conditions, and no later than 90 business days from the end of that period. The decision defines a business day as any day other than weekends and official Federal Government holidays, so the window runs to a little over four calendar months, and longer when public holidays fall inside it.
The trigger is the end of the tax period, not the date you realised you qualified. A fund with a 31 December 2026 year end that met the conditions during 2026 cannot apply in November. It waits for the period to close.
Registration comes first. The FTA must approve your tax registration before you can submit the exemption application, and registration timelines still follow FTA Decision No. 3 of 2024. Leaving registration until the exemption window opens is how entities miss both.
Which Deadlines Fall Before the End of 2026?
Three groups face a fixed date rather than a rolling window.
31 October 2026. A UAE juridical person wholly owned and controlled by a government entity or government-controlled entity must apply by 31 October for any tax period that ended before 1 January 2026. That is five weeks away, and it reaches back to periods beginning in June 2023.
31 December 2026, under Cabinet Decision 55. Cabinet Decision No. 55 of 2025, issued on 2 May 2025, extended exemption to foreign entities wholly owned and controlled by government entities, government-controlled entities, qualifying investment funds or pension funds, with retroactive effect to 1 June 2023 (Deloitte Middle East, 2025).
31 December 2026, for qualifying limited partnerships. Entities applying under Article 5 of Cabinet Decision No. 34 of 2025 share that date, for tax periods beginning in 2025 and ending on or before 31 August 2026. That decision replaced Cabinet Decision 81 of 2023 and brought REITs and qualifying limited partnerships into the regime (DLA Piper, 2025; full text on the Ministry of Finance site).
A Cabinet decision issued on or after 1 January 2026 reverts to the standard rule: 90 business days from the end of the tax period in which it was issued. Cabinet Decision No. 1 of 2026 on sports entities is the first to run that way.
How Does a Wholly Owned Subsidiary Apply?
The subsidiary can file, but it cannot be decided first. Where a juridical person under paragraph (h) or (i) is wholly owned and controlled by an entity under paragraph (f), (g) or (h), the subsidiary may submit its own application only once the parent has submitted one. The FTA then holds the subsidiary's application and makes no decision on it until the parent's application is approved.
For a fund with a holding structure underneath it, sequencing becomes the whole job. If the parent files late, every subsidiary sits frozen regardless of how early it filed.
What we see most often is a group that maps its ownership chain only when the first deadline is already close. Working out who owns what, and which paragraph of Article 4 each entity sits in, is work for now rather than December. Our corporate tax services cover that review.
The Cost of Missing the Window
The decision does not attach a penalty to a late exemption application. The exposure sits behind it: an entity that fails to secure exemption is a taxable person, filing a return and paying 9% on taxable income above AED 375,000 rather than lodging an annual declaration. An approved exemption runs from the start of the tax period named in the application, so a period you never applied for stays taxable.
Late registration carries an administrative penalty of AED 10,000. The FTA's waiver initiative removes it where the entity files its first corporate tax return, or its first annual declaration in the case of an exempt person, within seven months of the end of its first tax period (Federal Tax Authority, 2025). The waiver applies automatically on EmaraTax, and a penalty already paid comes back as a credit.
One question clients always ask is whether an exemption, once granted, needs renewing. It does not, but the conditions behind it have to keep being met, and the FTA can revisit status when they stop. Structures built around the participation exemption, family foundations or REIT ownership each carry their own conditions to monitor.
Frequently Asked Questions
Does an exempt person still have to file anything?
Yes. Exempt persons required to register file an annual declaration instead of a corporate tax return, due nine months from the end of the financial year. File the first one within seven months of the end of the first tax period to keep the AED 10,000 penalty waiver available.
Can I apply for exemption before my tax period ends?
No. Article 3 requires the application to be made after the end of the tax period in which the conditions were met. The 90-business-day clock only starts once that period closes.
What if the FTA thinks I named the wrong tax period?
The decision lets the FTA set a different effective date. It can move the start to the correct tax period where the registration form was wrong, to a later one where evidence shows the conditions were met then, or to an earlier one where the legislation applies retrospectively. An acquisition mid-period is handled the same way.
Does this change anything for free zone companies?
No. Qualifying free zone persons are taxable persons on a 0% rate for qualifying income, not exempt persons under Article 4, so they file a corporate tax return as normal and sit outside Decision 15 entirely.
My entity's tax period ended 31 December 2025. When do I apply?
Ninety business days from that date has already passed, so check whether a fixed date applies instead. A government-owned subsidiary can still apply by 31 October 2026 for periods ending before 1 January 2026, and Cabinet Decision 55 and Cabinet Decision 34 cases run to 31 December 2026. If none of those fit, the 30 September 2026 filing deadline and a standard return are the fallback.
If you run a fund, a foundation, a pension scheme or a holding company that sits under an exempt parent, the sequencing under Decision 15 is worth checking before 31 October. Get in touch and we will map your ownership chain against Article 4, confirm which deadline applies to each entity, and tell you what needs to be on EmaraTax and by when.