FTA Decision No. 15 of 2026, effective 15 September 2026, replaces Decision No. 7 of 2023 and sets new timelines for entities that must apply to be treated as Exempt Persons, including deadlines of 31 October 2026 and 31 December 2026 for certain retrospective claims.

Under the UAE Corporate Tax regime, some entities are exempt by law. Others are not. Qualifying Investment Funds, public and private pension and social security funds, certain wholly owned subsidiaries of exempt persons and other entities designated by Cabinet Decision only become Exempt Persons once they have registered for Corporate Tax and the Federal Tax Authority (FTA) has approved an application for exemption.

The FTA has now issued Decision No. 15 of 2026 on the provisions of exemption from Corporate Tax. The Decision was issued on 8 September 2026, took effect on 15 September 2026 and repeals FTA Decision No. 7 of 2023. It applies to Tax Periods commencing on or after 1 June 2023, in relation to applications submitted on or after 15 September 2026.

The Decision does not change the substantive conditions for exemption, which continue to be set out in the Corporate Tax Law and the relevant Cabinet and Ministerial Decisions. It is nonetheless highly relevant in practice. The procedure, and in particular the deadline, can determine whether an entity that meets those conditions is actually treated as an Exempt Person for a given Tax Period.

Which entities need to apply?

The Decision covers the categories of Exempt Persons listed in paragraphs (f), (g), (h) and (i) of Article 4(1) of Federal Decree-Law No. 47 of 2022 (the Corporate Tax Law), namely:

·        Qualifying Investment Funds.

·        Public or private pension or social security funds.

·        Juridical persons wholly owned and controlled by certain Exempt Persons.

·        Any other person exempted by a Cabinet Decision, such as the foreign entities wholly owned by certain exempt entities brought within scope by Cabinet Decision No. 55 of 2025.

Registration first, application second

The Decision confirms the sequence. These entities must first register for Corporate Tax in accordance with FTA Decision No. 3 of 2024. Only once the registration has been approved can they submit an application to be treated as an Exempt Person, provided that all applicable conditions are met.

An unregistered entity is therefore not in a position to apply, which makes registration timelines part of the exemption analysis.

What are the deadlines?

As a general rule, the application must be submitted after the end of the Tax Period in which the entity met the conditions for exemption, and no later than 90 Business Days from the end of that Tax Period. A Business Day is any day other than weekends and official Federal Government holidays.

This is a welcome extension compared with Decision No. 7 of 2023, which required the application to be submitted within 60 Business Days. The additional time is useful in practice, particularly for funds and pension structures that need to gather ownership, investor and activity information before confirming that the conditions have been met.

The Decision also sets specific deadlines where an exemption applies retrospectively. In practice, these rules give the entities concerned a new window to apply for periods for which they could not apply, or could no longer apply, under the general timeline:

·        Entities under paragraph (i) that qualify for retrospective exemption under Cabinet Decision No. 55 of 2025 must apply by 31 December 2026.

·        Where a Cabinet Decision granting a retrospective exemption is issued on or after 1 January 2026, the application must be submitted within 90 Business Days from the end of the Tax Period in which that Cabinet Decision is issued. This could be relevant, for example, for the exemption for certain sports entities introduced by Cabinet Decision No. 1 of 2026, which is among the instruments referred to in the Decision.

·        Juridical persons entitled to apply under Article 5 of Cabinet Decision No. 34 of 2025 on Qualifying Investment Funds and Qualifying Limited Partnerships, for Tax Periods that commenced during 2025 and end on or before 31 August 2026, must apply by 31 December 2026.

·        Juridical persons under paragraph (h) that are wholly owned and controlled by Government Entities or Government Controlled Entities may apply for any Tax Period that ended before 1 January 2026 no later than 31 October 2026, provided that the conditions for exemption were met in that Tax Period. This operates as an exception to both the general 90 Business Day deadline and the parent-first rule described below.

How are group structures handled?

Juridical persons under paragraphs (h) and (i) that are wholly owned and controlled by a Qualifying Investment Fund, a pension or social security fund or another paragraph (h) entity may only apply once their parent has applied. The FTA will not decide on the subsidiary's application until the parent's application has been approved.

For fund and pension structures with several layers of holding vehicles, the order and timing of the applications therefore matters. A delay at the top of the structure may delay certainty for every entity below it.

When does the exemption take effect?

Once approved, the exemption takes effect from the start of the Tax Period specified in the application. The FTA may determine a different effective date in certain scenarios, including where:

·        The Tax Period stated in the registration form is incorrect.

·        The applicant is acquired during a Tax Period by a Government Entity, a Government Controlled Entity, a Qualifying Investment Fund or a pension or social security fund. In this case, the exemption will apply from the start of a Tax Period commencing after all conditions are met.

·        The Tax Period stated in the application is incorrect and the FTA receives sufficient evidence that the conditions were met in the following Tax Period.

·        The legislation granting the exemption applies retrospectively, in which case the exemption applies from the start of the Tax Period in which the conditions are met.

The acquisition scenario is particularly relevant for transactions. A target acquired by an exempt investor will not necessarily be exempt from the date of the acquisition and may remain a Taxable Person for the Tax Period in which it is acquired.

What should businesses do now?

Funds, pension arrangements, and groups owned by exempt entities should consider:

·        Mapping every entity in the structure that relies, or intends to rely, on exempt status.

·        Confirming that each entity is registered for Corporate Tax and that the registration details, including the first Tax Period, are correct.

·        Identifying which deadline applies to each entity, with particular attention to 31 October 2026 and 31 December 2026.

·        Planning the sequence of applications for parent entities and their subsidiaries.

·        Documenting how the substantive conditions for exemption are met, including ownership, control and activity requirements.

·        Reviewing the expected Corporate Tax position of targets in acquisitions by exempt investors.

·        Monitoring Tax Periods in which the entity's profile changes, such as new investors, acquisitions or changes in activities.

Altair Tax Insight

Decision No. 15 of 2026 is a reminder that exempt status under UAE Corporate Tax is a procedure, not a label. An entity may meet every substantive condition and still not be treated as an Exempt Person for a given period if it has not registered and applied in time.

This is particularly relevant for asset managers, investment funds and holding structures that have been set up in, or moved to, the UAE in recent years. Exempt status should be reviewed as part of the structure's annual compliance calendar rather than assumed at set-up. The consequences of a missed deadline will depend on the specific facts, and each structure should be reviewed on a case-by-case basis.