The Federal Tax Authority (FTA) of the United Arab Emirates (UAE) has issued FTA Decision No. 15 of 2026 (New Decision), which replaces the erstwhile FTA Decision No. 7 of 2023 (Old Decision) in its entirety, and is applicable to tax periods commencing on or after 1 June 2023 effective from 15 September 2026.

While the compliance process for Corporate Tax (CT) registration and Exemption application remains unchanged for the relevant businesses, the New Decision introduces specific compliance timelines, addressing the erstwhile lack of clarity and practical challenges arising from the key legislative developments issued by the FTA in relation to Exempt Persons since the introduction of the UAE CT regime.

Key changes introduced in the New Decision

• Specific definition provided for “Business Day”, as follows:
  Any day of the week, except weekends and official holidays of the Federal Government.
• CT registration timelines for exempt persons are now aligned with the prescribed timelines as per the FTA Decision No. 3 of 2024, thereby eliminating the dates prescribed earlier which may no longer be relevant.
  You can access our tax alert in relation to the issuance of the FTA Decision No. 3 of 2024 on this link.
• Standard deadline for Exemption application extended from 60 to 90 Business Days from the end of the relevant tax period, with the following specific exceptions:

* Reference is drawn to CD 55 of 2025(Exempting Certain Persons)

** For example, reference is drawn to the recently issued CD 1 of 2026 (Exempting Certain Sports Entities)

Exempt person owned by another exempt person

• Exempt Persons that are wholly owned and controlled by any of the following categories of Persons shall be required to submit an Exemption application only after the Person that wholly owns and controls them has submitted its own application for Exemption:

   - Qualifying Investment Fund,
   - Public pension or social security fund,
   - Private pension or social security fund and/or
   - Any other juridical person wholly owned and controlled by an Exempt Person

• Approval of the exemption application shall also follow the same sequence as above.

Exemption approval and effective date

Approval and effective date provisions remain broadly unchanged, with a new clarification that where the relevant exemption legislation applies retrospectively, the exemption shall take effect from the start of the respective tax period in which the exemption conditions are met.

No specific clause on the filing of annual declaration

Although the specific reference to the requirement of furnishing an annual declaration confirming the fulfilment of the prescribed exemption conditions is now excluded under the New Decision, the filing obligation would continue to apply as per FTA Decision No. 11 of 2023 and is required to be complied with by the identified Exempt Persons on an annual basis within the prescribed timelines.

Key takeaways

As the New Decision became effective from 15 September 2026, please find below a summary of key takeaways and actions for the impacted entities:

• Exception timeline of 31 October 2026:

Entities owned by a government entity or a government controlled entity and meeting the prescribed Exempt Person requirements for any tax period ending before 1 January 2026 must submit their exemption application by 31 October 2026.

• Exception timeline of 31 December 2026:

POEM entities and qualifying limited partnerships meeting the prescribed Exempt Person requirements in respect of tax periods that commenced during calendar year 2025 and ended on or before 31 August 2026 must submit their exemption application by 31 December 2026.

• Exception timeline of 90 days deadline for retrospective exemptions:

Sports entities eligible for retrospective exemption as per CD 1 of 2026 must submit their exemption application(s) for all the relevant tax periods within the prescribed timeline of 90 days from the end of tax period in which CD is issued (i.e., latest by 31 March 2027, as CD 1 of 2026 was issued on 12 January 2026), once the prescribed form is made available on the Emara Tax portal.

• Extension of standard deadline:

Whilst this extension from 60 to 90 business days provides additional time, the eligible entities should not wait until the final deadline to begin preparing their Exemption application.

• Annual declaration:

Requirement to file an annual declaration that existed under the Old Decision seems to have been excluded under the New Decision.
However, this annual filing obligation would continue to apply for the identified Exempt Persons as per FTA Decision No. 11 of 2023.

• Systemic exemption application requirement:

Subsidiaries of exempt entities must note the new systemic exemption application requirement where the controlling parent's exemption application must be submitted and approved before the subsidiary's exemption can be granted. Entities should map out their application sequencing immediately to avoid any compliance delays.

• Update of tax governance documents:

All internal processes, templates, and tax governance documents of the Exempt Persons that referenced to the Old Decision must now be updated to reflect the New Decision to ensure accurate and timely compliances.