A corporate tax assessment is the analytical work that should precede every UAE corporate tax return — identifying the exact taxable income, applying every available relief correctly, documenting the legal basis for every adjustment, and confirming that the return will be filed on the most accurate and commercially defensible basis possible. For most UAE businesses filing their first or second return, the assessment reveals that their tax position is materially more complex than 9% applied to accounting profit. Related-party transactions that have never been tested for arm’s length compliance create transfer pricing risk. Free zone entities may have income classified as qualifying when the FTA’s qualifying activity definitions do not support that classification. First-year elections that can only be made once — and cannot be undone — may have been overlooked. Risians conducts corporate tax assessments for UAE mainland and free zone businesses, delivering a written taxable income calculation with the legal basis documented for every adjustment — the foundation of a return the FTA cannot challenge without clear evidence.
A corporate tax assessment is the analytical process of determining precisely what a UAE business owes in corporate tax — and what it does not — before the return is filed. It is not the same as preparing the return. It is the step before it, where every material position is identified, every available relief is analysed, and every risk is documented so that the return is filed on the most accurate and commercially defensible basis possible.
For most UAE businesses, the first corporate tax assessment coincides with the first return. And for most first-time UAE corporate tax filers, the assessment reveals that the tax position is not simply 9% applied to accounting profit. Expenses that are entirely legitimate from an accounting perspective may not be deductible for tax. Related-party transactions that have never been reviewed for arm’s length compliance may have transfer pricing implications. Free zone entities may have income they have not classified correctly as qualifying or non-qualifying. First-year elections that can only be made once — and that can have a material impact on the tax liability — may not have been identified.
Risians Accounting & Tax Consultancy provides corporate tax assessment services for UAE businesses across all structures — mainland companies, free zone entities, natural persons, and subsidiaries of international groups. We deliver a written, documented taxable income calculation that forms the foundation of a return the FTA cannot challenge without clear evidence.
A corporate tax assessment is only as valuable as the knowledge behind it. Risians brings three elements that most accounting firms in Dubai cannot offer together: FTA-registered tax agent status that means we have worked through the EmaraTax system on behalf of clients; DMCC-approved audit experience that means we understand the intersection of free zone authority requirements and federal tax law; and current-law depth that reflects every FTA Public Clarification and Ministerial Decision issued since the law’s enactment. The assessment we produce is not a generic reconciliation template — it is a specific, documented analysis of your business’s actual position under UAE corporate tax law as it stands in 2026.
The starting point is the net profit in the financial statements. From there, a structured reconciliation adjusts for non-deductible expenses, exempt income, elections, and specific tax treatments to arrive at taxable income. Every adjustment is documented with the legal basis from the UAE Corporate Tax Law, the relevant Ministerial Decision, or the relevant FTA Public Clarification. This documentation is what makes the return defensible in an FTA audit.
Interest expense is subject to a 30% EBITDA cap for businesses with deductible interest above AED 12 million per year — excess interest is disallowed in the current period but can be carried forward. Entertainment expenses are deductible at 50%. Fines and penalties paid to government authorities are not deductible. Payments to related parties above arm’s length rates are disallowed. Personal expenses that are not wholly and exclusively for business purposes are disallowed. Correctly identifying each category ensures the taxable income figure is neither overstated nor understated.
Qualifying dividends from UAE and foreign subsidiaries — where shareholding, holding period, and ownership conditions are met — may be excluded from taxable income under the participation exemption. Capital gains on qualifying shareholding disposals may similarly be exempt. Risians identifies all exempt income streams and documents the legal basis for each exemption applied.
SBR eligibility requires that revenue has not exceeded AED 3 million in the current period or any prior period. Risians verifies the revenue position for every relevant year and documents the basis for the eligibility claim. Critically, Risians also advises on whether electing SBR is actually in the business’s interest — a loss-making business that elects SBR forfeits the right to carry that loss forward, which may cost more in future tax than the current-period saving is worth.
The Small Business Relief election is one of the most frequently misunderstood provisions in UAE corporate tax. It is available to businesses with annual revenue not exceeding AED 3 million in the current and all prior tax periods, and it treats taxable income as zero for that period — eliminating the current-year tax liability entirely. But electing SBR also forfeits the right to carry forward any tax losses arising in that period to offset future taxable income. For a loss-making business, this trade-off may not be in its long-term financial interest: the current-period tax saving is zero in any case because there is no taxable income, but losing the carry-forward means future profitable periods bear more tax than they otherwise would. Risians models the multi-year financial impact of the SBR election for every client before recommending it — and declines to recommend it in cases where the long-term cost exceeds the current-period benefit.
Maintaining QFZP status requires meeting all six conditions every year. Risians conducts a structured analysis covering: qualifying activity classification for each income stream; UAE substance adequacy relative to the activities conducted; non-qualifying revenue against the de minimis threshold (lower of AED 5 million or 5% of total revenue); related-party transaction arm’s length compliance; financial statement audit requirement; and GAAR risk assessment. Where QFZP risk factors are identified, Risians advises on operational or structural mitigations before the return is filed.
All transactions between related parties and connected persons must be at arm’s length. Businesses with related-party transaction volumes exceeding AED 40 million in a tax period must maintain a Local File available within 30 days of FTA request. Risians reviews all intercompany transactions, benchmarks pricing against arm’s length ranges, prepares Local File and Master File documentation where required, and identifies any positions that could be challenged.
The realization basis election for capital gains and the transitional relief for pre-CT assets — including qualifying immovable property and certain intangible assets — can only be elected in the first corporate tax return. Both can have material impacts on tax liability in the first period and beyond. Risians identifies every first-year election available to each client and provides a specific recommendation on whether to make it.
Tax losses can be carried forward to offset up to 75% of taxable income in future periods. Loss utilisation is subject to ownership continuity conditions. Where a Tax Group exists or is being considered, loss offset across group members is an additional dimension. Risians documents the loss position and its carry-forward availability as part of every assessment.
The UAE corporate tax law contains a General Anti-Avoidance Rule (GAAR) that allows the FTA to disregard arrangements whose principal purpose is obtaining a tax advantage that is not consistent with the intent of the law. In 2026, as corporate tax enforcement matures, GAAR application is becoming an active FTA focus — particularly for QFZP structures, related-party arrangements, and intercompany financing that appear designed to shift profits rather than reflect commercial reality. Risians assesses every client engagement for GAAR risk, identifies arrangements that could attract FTA scrutiny, and advises on restructuring or documentation that supports the commercial substance of the tax position taken. A tax position that is technically correct but lacks commercial substance is a GAAR risk — and Risians identifies these before they become audit findings.
Defining the critical distinction between tax assessments and tax returns, managing Transfer Pricing (TP) obligations, and navigating the independence requirements for audit and tax services.
Yes — they are sequential steps. A CT assessment is the analytical work that precedes the return: calculating taxable income from accounting profit, identifying and applying every available relief and adjustment, and documenting the legal basis for each position. A CT return is the formal legal document filed through EmaraTax within nine months of year-end that declares the taxable income and tax payable based on the assessment. Filing a return without an assessment means filing without a documented basis for your positions — which creates FTA exposure if any adjustment is later questioned. Risians delivers the assessment as a written document first, reviews it with you, and then prepares and files the return from it. The assessment is your legal defence document; the return is your formal declaration.
All related-party transactions must be at arm's length — this is the standard from the first period, regardless of documentation threshold. The formal documentation requirement (Local File) applies when your aggregate related-party transactions in a tax period exceed AED 40 million. The Local File must be prepared and available within 30 days of an FTA request — you do not file it with the return, but it must exist on demand. Businesses below AED 40 million still have transfer pricing risk — the arm's length standard applies — but are not required to produce a formal Local File unless the FTA specifically requests one. Risians assesses both the pricing of your related-party transactions and the documentation required, and produces Local File documentation for all clients above the threshold as part of the annual assessment engagement.
Both. The assessment identifies every available reduction to your taxable income — deductions you are entitled to but may not have identified, reliefs that apply to your business structure, elections that reduce the liability for the current period, and loss positions that can be carried forward. Risians has identified material tax reductions in a significant proportion of first-year assessment engagements — not through aggressive tax planning, but through correct application of relief provisions that clients were unaware of or had not applied. The assessment also prevents over-payment — businesses that pay more CT than they are legally required to have no automatic refund mechanism; the overpayment is simply a credit that must be claimed or carried forward. Getting the assessment right from the first period protects you in both directions.
Every year. The CT assessment is not a one-time exercise — it is an annual analytical process because your business changes year to year. New revenue streams may create new qualifying or non-qualifying income classifications. Capital expenditure creates new depreciation and potential impairment issues. New intercompany transactions require arm's length analysis. SBR eligibility may change as revenue crosses or falls below the AED 3 million threshold. FTA guidance evolves — new Public Clarifications and Ministerial Decisions are issued periodically and may change the correct treatment of specific transactions. A second-year return filed without a current-year assessment is just as exposed as a first-year return filed without one. Risians conducts a CT assessment for every client every year as a mandatory step before the return is prepared.
UAE Corporate Tax provides specific exemptions for: qualifying dividends received from UAE or foreign subsidiaries (subject to the participation exemption conditions), capital gains on the disposal of qualifying shareholdings (same conditions), income of qualifying investment funds, and income that is out of scope (employment income, personal investment returns). The participation exemption conditions require the shareholding to be at least 5%, held for at least 12 months (or the intention to hold for 12 months), and the subsidiary not to be in a jurisdiction below 9% tax rate without an objective non-tax reason. Incorrectly claiming an exemption creates an immediate CT underpayment liability. Risians analyses the eligibility of every income category in your accounts against the applicable exemption conditions as part of the CT assessment.
Capital expenditure (capex) is not immediately deductible — it is capitalised as a fixed asset and depreciated over its useful life. The annual depreciation charge is deductible for CT purposes (provided it meets the business purpose and arm's length standards). However, there are specific CT considerations: the treatment of capex financed by intercompany loans (interest deductibility subject to the 30% EBITDA cap), whether the asset qualifies for accelerated depreciation, and whether the capex was on a right-of-use asset under IFRS 16 that generates both depreciation and interest charges — both of which require specific CT analysis. For businesses making significant capex decisions, Risians provides pre-acquisition tax impact analysis as part of the CFO and assessment service so the CT implications are known before the capital is committed.
The assessment deliverable Risians produces is a written document with a specific legal basis cited for every adjustment — not a spreadsheet calculation with no supporting rationale. Each line of the accounting profit-to-taxable-income reconciliation references the applicable article of the UAE CT law, the relevant Ministerial Decision, or the FTA Public Clarification that supports the treatment applied. This documentation structure is specifically designed to be produced to the FTA in response to a challenge. Risians' FTA-registered tax agent status means we can represent your business directly in any FTA challenge arising from the return, using the assessment documentation as the basis of the defence. Our internal review process also involves a second-reviewer check on every assessment before it is delivered — the position we advise on is a position we are prepared to defend.
Your statutory auditor's role is to give an independent opinion on your financial statements — they are specifically required to be independent of management and cannot also be preparing the management figures they are auditing. Preparing your CT assessment — which involves management judgment on tax positions — is a management function, not an audit function. While the same firm can do both in the UAE (with appropriate independence safeguards), the skills required are different: CT assessment requires tax law expertise and FTA enforcement knowledge, while audit requires financial statement verification expertise. Risians provides CT assessments using our tax advisory team and, as a DMCC-approved auditor, can also provide the statutory audit — but the two teams operate with appropriate independence protocols. For businesses where auditor independence is a specific concern, we structure the engagement accordingly.
The difference between a corporate tax return that is accurate and one that creates an FTA liability is the pre-filing assessment. Related-party transactions that have never been tested for arm’s length compliance, first-year elections that cannot be undone once the return is filed, QFZP conditions that have not been reviewed against the qualifying activity rules — these are the issues that a corporate tax assessment identifies and addresses before they become audit findings. Contact Risians to commission a corporate tax assessment before your next return is prepared. We deliver a written taxable income calculation with the legal basis documented for every adjustment — the foundation your return needs.
Risians Accounting & Tax Consultancy is an FTA-certified accounting, auditing, and tax advisory firm. Based in Downtown Dubai, we provide comprehensive financial solutions to businesses throughout the UAE.
