The Ministry of Finance (MoF) announced the repeal of Ministerial Decision No. 265 of 2023, replacing it with Ministerial Decision No. 229 of 2025 on Qualifying Activities and Excluded Activities, which clarifies the scope of Qualifying Activities for Corporate Tax purposes in Free Zones.
The new updates expand the scope of Qualifying Commodity Trading to include industrial chemicals, associated by-products of qualifying commodities, and environmental commodities.
UAE tax rules
They also provide clarifications on Treasury and financing services for Related Parties.
In addition, the MoF has issued Ministerial Decision No. 230 of 2025 on the Specification of Recognised Price Reporting Agencies for the purposes of Ministerial Decision No. 229 of 2025.
Ministerial Decision No. 229 of 2025 removes the previous reference to commodities being traded only “in raw form.”
The scope now allows the trading of metals, minerals, industrial chemicals, energy, and agricultural commodities, as well as associated by-products, provided a Quoted Price exists.
A Quoted Price refers to the price of a qualifying commodity or related commodity specified by a Recognised Commodity Exchange Market or a Recognised Price Reporting Agency designated by the Minister.
Ministerial Decision No. 230 of 2025 lists the recognised pricing agencies, giving taxpayers certainty and clarity in applying the rules.
Other beneficial changes include:
- Recognition of self-investment within the Qualifying Activity of Treasury and financing services, whether for Related Parties or the taxpayer’s own account
- Clarification that the distribution of goods or materials in or from a Designated Zone allows transactions with public benefit entities without impacting the de-minimis threshold
The Ministry of Finance emphasised the pivotal role of Free Zones in driving the UAE’s economic growth, attracting investment, and fostering an enabling business environment.
It said the new decisions “reflect the importance of Free Zones and their role in the country’s economic diversification strategy, as well as the UAE’s commitment to providing a supportive business environment in alignment with international tax standards.”
The Ministry added that the UAE’s competitive Corporate Tax regime, combined with preferential tax treatment for Qualifying Activities, reinforces the nation’s position as a leading global hub for business and investment, while advancing its sustainable development agenda.
