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UAE FTA Decision 15 sets 31 October deadline for some government-owned companies seeking retrospective Corporate Tax exemption
Federal Tax Authority Decision No. 15 of 2026, effective 15 September, replaces the 2023 exemption procedure. Wholly owned Article 4(1)(h) entities controlled by government or government-controlled persons can still claim exemption for Tax Periods that ended before 1 January 2026 — but only if they apply by 31 October.
The UAE Federal Tax Authority has reset how eligible persons apply for Corporate Tax exemption. Decision No. 15 of 2026 was issued on 8 September and took effect on 15 September 2026. It repeals FTA Decision No. 7 of 2023. The Authority lists the Decision on its Corporate Tax legislation page; the English PDF is marked as an unofficial translation, with Arabic governing.
Who faces the nearest clock: under Article 3(5), a juridical person in Article 4(1)(h) of the Corporate Tax Law that is wholly owned and controlled by a person in Article 4(1)(a) or (b) — government entities or government-controlled entities — may apply for exemption for any Tax Period that ended before 1 January 2026 no later than 31 October 2026, provided the exemption conditions were met for that period.
The ordinary rule for persons in Article 4(1)(f), (g), (h) and (i): apply after the Tax Period in which the conditions were met, and no later than 90 Business Days after that period ends. Business Day means any day except Federal Government weekends and official holidays. Eligible persons in those categories must also register for Corporate Tax first under FTA Decision No. 3 of 2024 before seeking exemption.
Other transitional cut-offs in the same Decision include 31 December 2026 for certain retrospective routes tied to Cabinet Decision No. 55 of 2025 and to Article 5 of Cabinet Decision No. 34 of 2025. Where a company under (h) or (i) is wholly owned and controlled by a person in category (f), (g) or (h), it may apply only once that owner has applied, and the FTA will not decide its application until the owner's is approved. The 31 October catch-up for companies owned by government entities is expressly an exception to that sequencing rule (Article 3(5)).
Why it matters: exemption is a procedure with a deadline, not an automatic status. Groups with government-owned holding chains that skipped earlier periods now have a short window to file for pre-2026 periods before 31 October, then to keep the 90-Business-Day clock for ongoing periods.
Sources: FTA Decision No. 15 of 2026 (PDF on tax.gov.ae); FTA Corporate Tax legislation index.
Watch next: how EmaraTax surfaces the exemption application forms for Article 4(1)(h) catch-up filings, and whether advisers publish Arabic-authoritative checklists against the official text.