The Ministry of Finance has issued Ministerial Decision (‘MD’) No. 229 of 2025 regarding Qualifying Activities and Excluded Activities for determining qualifying income of a Qualifying Free Zone Person under UAE Corporate Tax (‘CT’) Law. This new decision repeals and supersedes MD No. 265 of 2023 from 1 June 2023.
A summary of key changes and updates introduced through the MD No 229 of 2025 is tabulated below:
| Particulars | MD No. 265 of 2023 (Old) | MD No. 229 of 2025 (New) |
| Qualifying Commodities included | Metals, minerals, energy, and agricultural commodities that are traded on a recognized commodity exchange market in raw form | Scope enhanced to include the following commodities provided a quoted price exists:
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| Recognised Commodities Exchange Market | Any commodities exchange market licensed by relevant competent authority in the UAE or outside of the UAE of equal standing | Any commodities exchange market:
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| Treasury & Financing Services | Limited to Related Parties | Extended to Related Parties as well as for its own account |
| Trading of Qualifying Commodities | Included physical trading and associated derivative trading used to hedge against risks involved in such activities | Scope enhanced to include associated structured commodity financing activity
Provided the activity is not done by a QFZP whose 51% or more of revenue is derived from distribution, warehousing, logistics or inventory management function |
| Distribution of goods or materials in or from a Designated Zone | Only included buying and selling of goods or materials to a customer who resells such goods or materials or parts thereof or processes or alters such goods or materials or parts thereof for the purposes of sale or resale | Scope enhanced to include supply of goods or materials to Public Benefit Entity |
| Recognised Price Reporting Agencies | N.A. | MD No. 230 of 2025 on Specification of Recognised Price Reporting Agencies has enlisted the following recognised price reporting agencies for the purposes of MD. 229 of 2025:
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Considering these changes, it is imperative for the businesses to re-evaluate their tax positions, specifically in cases where the Corporate Tax return has already been filed.