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.
You can file without a prior assessment, but the risk of doing so is that you file inaccurately — either overpaying by missing available reliefs, or underpaying by not identifying non-deductible expenses or transfer pricing issues. Correcting a filed return is more expensive and more time-consuming than getting it right before filing. For businesses filing their first return, Risians considers a pre-filing assessment essential.
Non-deductible categories include: fines and penalties paid to government authorities; entertainment expenses above the 50% cap; interest in excess of the 30% EBITDA limit for businesses above the AED 12 million interest threshold; payments to related parties above arm's length rates; and expenses with no identifiable business purpose. Risians identifies all non-deductible amounts in the reconciliation as part of the assessment.
The participation exemption excludes qualifying dividends and capital gains from UAE corporate tax, provided specific shareholding and holding period conditions are met. For businesses with significant investment income from subsidiaries, correctly applying the participation exemption can materially reduce taxable income. Risians analyses each dividend and disposal against the exemption conditions.
Losing QFZP status results in 9% corporate tax being applied to the entity's total income — not just non-qualifying income — for the year of loss and the following four consecutive years. This is one of the highest-value risks in UAE corporate tax for free zone businesses. Risians' annual QFZP eligibility assessment is specifically designed to identify risk factors before status is lost, not after.
No. UAE corporate tax losses can be carried forward to offset up to 75% of taxable income in future periods, but cannot be carried back. There is no cap on how many years losses can be carried forward, but ownership continuity conditions apply. Businesses considering electing Small Business Relief for a loss-making period should note that doing so forfeits the right to carry that period's loss forward.
An FTA-certified accounting, auditing & tax advisory firm based in Downtown Dubai, serving businesses across the UAE.
