--- title: "A UAE exemption now has a deadline, and the parent must file first" url: https://www.boruconsulting.com/blog/fta-decision-15-2026-exemption-deadlines category: "Regulatory Intelligence" author: "Ruairi Laughlin-McCann" published: 2026-10-14 modified: 2026-10-14 --- # A UAE exemption now has a deadline, and the parent must file first > A UAE fund, pension vehicle or holding company does not become exempt by qualifying. FTA Decision 15 of 2026 made the exemption a timed filing, with two catch-up deadlines in late 2026 and a rule that the parent must be approved before any subsidiary beneath it. The order of filing now decides who is exempt, and when. ## Key Takeaways - Decision 15 of 2026 is procedural, not substantive. It does not change who qualifies for exemption, which still turns on the corporate tax law and the Cabinet Decisions beneath it. It changes when, and in what order, a fund, pension vehicle or wholly owned subsidiary has to apply, and an entity that meets every condition is still a taxable person at 9% for a period if it has not registered and applied in time. - Two catch-up deadlines fall in late 2026. A juridical person wholly owned and controlled by a Government or Government Controlled Entity has until 31 October 2026 to claim exemption for periods ended before 1 January 2026. A foreign entity exempt under Cabinet Decision No. 55 of 2025, and a Qualifying Investment Fund or qualifying limited partnership under Cabinet Decision No. 34 of 2025 for 2025 periods ending on or before 31 August 2026, has until 31 December 2026. - Register first, then claim. Under FTA Decision No. 3 of 2024 an entity must be registered for corporate tax before it can apply for exempt status, so an unregistered vehicle cannot even start. The standard application window is now 90 business days after the end of the tax period in which the conditions were met, extended from the 60 business days that Decision No. 7 of 2023 allowed. - The parent files first. A subsidiary wholly owned and controlled by a fund, a pension fund or another exempt holding entity cannot have its exemption decided until the parent's application has been approved. In a multi-tier DIFC, ADGM or mainland holding stack that makes the order of filing decisive, because a delay at the top delays certainty for everything beneath it. - Exemption is not automatic on acquisition. Where an exempt investor acquires a company mid-period, the company is not necessarily exempt from the date of acquisition and can remain taxable for the whole of that tax period, with the exemption running only from the start of the next one. The effective date is a question in its own right in any transaction. ## The exemption was always a filing, and now it has a clock The point that families and fund managers miss about UAE exemption is that it is a status you apply for, not a nature you are born with. A Qualifying Investment Fund, a pension vehicle, a holding company owned by one of those, none of them is exempt because of what it is. Each is a taxable person at 9% until it has registered, applied to the Federal Tax Authority, and been approved. That was already the law, and it is set out in the note on [how a UAE family structure earns its exemption](https://www.boruconsulting.com/blog/uae-corporate-tax-exemption-family-structures). What changed in September 2026 is the clock. FTA Decision No. 15 of 2026 was issued on 8 September 2026, took effect on 15 September 2026, and repealed the earlier FTA Decision No. 7 of 2023. It does not touch the conditions for exemption, which still live in Federal Decree-Law No. 47 of 2022 and the Cabinet Decisions beneath it. It governs the procedure, and in particular the timing and the order of the applications, and the procedure is now capable of deciding whether an entity that genuinely qualifies is actually treated as exempt for a given year. That is the uncomfortable part. A fund can meet every substantive test and still be a taxable person for a period, because it registered late, applied late, or applied in the wrong order. The decision turns the exemption from a quality of the structure into a filing on a deadline, and it puts two of those deadlines inside the last quarter of 2026. This note sets out what the decision changed, the dates that bite, the sequencing rule that catches multi-tier structures, and when the exemption actually begins once it is granted. ## What Decision 15 of 2026 changed, and what it left alone It helps to be precise about the boundary of the decision, because the headlines have blurred it. Decision 15 leaves the substance alone. Who is an exempt person, what a Qualifying Investment Fund has to look like, when a foreign holding company owned by an exempt person falls inside the exemption, all of that is still governed by the corporate tax law and by Cabinet Decision No. 55 of 2025 and Cabinet Decision No. 34 of 2025. The decision does not widen or narrow the categories. If a structure did not qualify before, it does not qualify now, and reading the decision as a new relief is a mistake. What the decision changes is the administration. It applies to the exempt-person categories in Article 4 of the corporate tax law, the Qualifying Investment Funds, the public and private pension and social security funds, the juridical persons wholly owned and controlled by certain exempt persons, and the further categories brought in by Cabinet Decision. It confirms the order of the steps, resets the application windows, and sets specific catch-up dates for positions that were taken before the machinery existed to claim them. It applies to tax periods beginning on or after 1 June 2023, for applications made from 15 September 2026 onward. The most useful change for anyone still inside a window is the length of it. Under the old Decision No. 7 of 2023 an eligible entity had 60 business days after the end of its tax period to apply. Decision 15 extends that to 90 business days, counting any day that is not a weekend or a federal public holiday. For a fund or pension structure that has to assemble ownership, investor and activity information before it can confirm it qualifies, the extra month of working days is a genuine help, not a technicality. ## Register first, then claim the status The decision confirms an order that trips up more structures than any single condition does. Exemption is the second step, not the first. An entity in one of these categories has to register for corporate tax under FTA Decision No. 3 of 2024 before it can apply to be treated as an exempt person. Only once the registration is approved can the exemption application be made, and only then if the entity meets all of the applicable conditions. An entity that has not registered is not in a position to apply at all, which means the registration timeline sits inside the exemption analysis rather than beside it. A fund that assumes it is outside the system because it expects to be exempt has the sequence backwards, and the assumption costs it the clock. This is why the practical work starts with a map, not a form. Every entity in the structure that relies, or intends to rely, on exempt status has to be identified, its registration confirmed, and its first tax period checked for accuracy, before any application is lodged. The registration details, and the first tax period in particular, decide the window that then applies. ## The two deadlines that fall in late 2026 Alongside the standard 90-business-day rule, Decision 15 opens specific catch-up windows for entities that could not previously apply, or whose general window had already closed. Two of them fall before the end of 2026, and they are the reason this is a Q4 2026 problem rather than a general one. The first is 31 October 2026. A juridical person wholly owned and controlled by a Government Entity or a Government Controlled Entity can claim exemption for any tax period that ended before 1 January 2026, provided the conditions were met in that period, up to that date. This window is an exception both to the general 90-business-day rule and to the parent-first sequencing rule described below. The second is 31 December 2026, and it is the one that reaches private capital. A foreign entity that is entitled to retrospective exemption under Cabinet Decision No. 55 of 2025, the decision that brought a foreign company wholly owned by an exempt person inside the exemption, has until 31 December 2026 to apply. So does a Qualifying Investment Fund or a qualifying limited partnership entitled to apply under Article 5 of Cabinet Decision No. 34 of 2025, for tax periods that began during 2025 and end on or before 31 August 2026. A family or fund structure that has been operating as though its holding layer or its fund was already exempt, without having filed, is squarely inside this window, and the window shuts at the year end. The table sets the main cases against their deadlines. | Who is applying | Which tax periods | Deadline to apply | | --- | --- | --- | | Juridical person wholly owned and controlled by a Government or Government Controlled Entity | Any period ending before 1 January 2026 | 31 October 2026 (an exception to the 90-day and parent-first rules) | | Foreign entity exempt under Cabinet Decision No. 55 of 2025 | Retrospective periods it could not previously claim | 31 December 2026 | | Qualifying Investment Fund or qualifying limited partnership under Article 5 of Cabinet Decision No. 34 of 2025 | 2025 periods ending on or before 31 August 2026 | 31 December 2026 | | Entity under a later Cabinet Decision granting exemption from 1 January 2026, such as qualifying sports entities under Cabinet Decision No. 1 of 2026 | The period in which that Decision is made | Within 90 business days of the end of that period | | Any eligible entity, going forward | The period in which the conditions are first met | Within 90 business days of the end of that period | ## The parent files first The rule most likely to catch a well-advised group is not a date at all. It is an order. A juridical person that is wholly owned and controlled by a Qualifying Investment Fund, by a pension or social security fund, or by another exempt holding entity, can only apply once its parent has applied. More than that, the Federal Tax Authority will not decide the subsidiary's application until the parent's application has been approved. The subsidiary cannot jump the queue, and it cannot be granted exemption while the entity above it is still pending. For a single company owned by a single fund that is a formality. For the structures this actually affects it is a bottleneck, because they are rarely single-layer. A DIFC or ADGM fund platform, or a mainland holding group, tends to run several tiers, a fund at the top, an intermediate holding company, then the asset-holding vehicles beneath. Under the parent-first rule the top of that stack has to be filed and approved before the certainty flows down to the rest, and a delay or a query at the top holds up every entity that depends on it. The order of filing becomes a project to manage, with the parent entity's application as the critical path and the subsidiaries sequenced behind it, not submitted in parallel and left to sort themselves out. The 31 October 2026 government-owned case is the one exception the decision carves out of this rule. Everywhere else, the sequence holds, and a group that files bottom-up, or all at once, can find the subsidiaries stalled behind an unapproved parent with the clock still running. ## When the exemption actually begins Approval is not the end of the question, because the date the exemption takes effect is a separate matter, and it is not always the date the applicant would choose. As a rule, once the application is approved the exemption runs from the start of the tax period specified in the application. The Federal Tax Authority can fix a different effective date in defined situations, and two of them matter in practice. The first is a correction case, where the tax period in the registration was wrong, or where the evidence shows the conditions were in fact met in a later period than the one claimed. The second is the one that reaches into transactions. Where an entity is acquired during a tax period by a Government Entity, a Government Controlled Entity, a Qualifying Investment Fund or a pension fund, the exemption applies only from the start of the tax period that begins after all of the conditions are met. In plain terms, a company bought by an exempt investor is not automatically exempt from the day the deal closes. It can remain a taxable person for the whole of the tax period in which it was acquired, and become exempt only from the next period. In a transaction that assumes the target drops into the acquirer's exempt status on completion, that gap is a real liability, and it belongs in the tax structuring of the deal rather than in a surprise at the first return. ## What this means for a corridor family For a family or a fund group connected to the United Kingdom or Ireland, the decision changes the calendar, not the geography. The exemption it governs is a UAE exemption, and it stops at the UAE border. A structure that becomes an exempt person in the UAE is still a company, a settlement or a fund in the country where the family actually lives, and the home-country rules read it on their own terms. A UK-resident settlor or controller still meets the settlements code, the transfer-of-assets rules and the controlled-foreign-company rules, whatever the UAE return shows, as the note on [the post-non-dom UAE structure and the UK rules](https://www.boruconsulting.com/blog/post-non-dom-uae-cfc) sets out, and the way a family office itself should be built across the corridor is examined in the note on [where a UAE family office belongs](https://www.boruconsulting.com/blog/uae-family-office-difc-adgm-corporate-tax). Getting the UAE filing right on time is necessary, and it is not sufficient. The practical message is narrow and urgent. If a structure relies on an exemption that has not yet been applied for, the position has to be mapped now, the entities registered, the right window identified, and the applications sequenced from the parent down, with the two 2026 dates treated as hard. The 9% is the default the moment the clock runs out, and after the year end a missed retrospective window does not reopen. ## Frequently asked questions ### What is FTA Decision No. 15 of 2026? It is the Federal Tax Authority decision that governs how an exempt person applies for and keeps exempt status under UAE corporate tax. It was issued on 8 September 2026, took effect on 15 September 2026, and repealed the earlier FTA Decision No. 7 of 2023. It is a procedural instrument. It sets the registration order, the application windows, the sequencing of parent and subsidiary applications, and the effective date of the exemption, without changing the substantive conditions that decide who qualifies. ### Does Decision 15 change who qualifies for UAE corporate tax exemption? No. The categories of exempt person, and the conditions attached to each, remain governed by Federal Decree-Law No. 47 of 2022 and the Cabinet Decisions beneath it, including Cabinet Decision No. 55 of 2025 and Cabinet Decision No. 34 of 2025. Decision 15 only governs the process of claiming and maintaining the status. A structure that did not qualify before the decision does not qualify because of it, and one that did qualify still has to apply correctly and on time to be treated as exempt. ### What are the 31 October and 31 December 2026 deadlines? They are catch-up windows for positions taken before the current machinery existed. By 31 October 2026, a juridical person wholly owned and controlled by a Government or Government Controlled Entity can claim exemption for periods that ended before 1 January 2026. By 31 December 2026, a foreign entity exempt under Cabinet Decision No. 55 of 2025, and a Qualifying Investment Fund or qualifying limited partnership under Cabinet Decision No. 34 of 2025 for 2025 periods ending on or before 31 August 2026, must apply. The 31 December date is the one that reaches most private structures. ### What is the parent-first rule? It is the sequencing rule in Decision 15. A subsidiary wholly owned and controlled by a Qualifying Investment Fund, a pension fund or another exempt holding entity can only apply for exemption once its parent has applied, and the Federal Tax Authority will not decide the subsidiary's application until the parent's has been approved. In a multi-tier holding structure the top entity has to be filed and approved before the entities beneath it can be, so the applications have to be sequenced from the top down rather than submitted together. ### How long do I now have to apply for exempt status? The standard window is 90 business days from the end of the tax period in which the entity first met the conditions for exemption, counting any day that is not a weekend or a federal public holiday. This is an extension from the 60 business days allowed under the previous Decision No. 7 of 2023. The retrospective catch-up windows, including the 31 October and 31 December 2026 dates, are separate and apply to specific categories and periods rather than to the general rule. ### Do I have to register for corporate tax before applying for exemption? Yes. Under FTA Decision No. 3 of 2024 the entity must be registered for corporate tax before it can apply to be treated as an exempt person, and the exemption application can only be made once that registration is approved. An unregistered entity cannot apply, so the registration timeline is part of the exemption analysis. The first tax period recorded on the registration also drives the application window, so an error there can affect the deadline that applies. ### If an exempt investor acquires my company, is it exempt straight away? Not necessarily. Where a company is acquired during a tax period by a Government Entity, a Government Controlled Entity, a Qualifying Investment Fund or a pension fund, the exemption applies only from the start of the tax period beginning after all of the conditions are met. The company can remain a taxable person for the whole of the period in which it was acquired, and become exempt only from the next one. In a transaction, that effective-date gap should be modelled rather than assumed away. ### We are UK resident with a UAE structure. Does getting the exemption right in the UAE settle our position? Only the UAE side of it. A UAE exempt person is still a company, settlement or fund under UK law, so a UK-resident settlor, beneficiary or controller can still face the settlements code, the transfer-of-assets rules, the controlled-foreign-company rules and inheritance tax on the same structure. Filing the exemption correctly and on time removes the UAE charge for the period; it does not remove the UK one. For a corridor family the UAE deadlines and the home-country position have to be managed together. --- **Critical advisory.** The costliest version of this is the structure that has treated an exemption as already in place for two or three years without ever filing for it, and now meets a hard year-end date to put that right. Decision 15 of 2026 made exemption a timed, ordered filing, and the two 2026 windows do not reopen once they close. We register UAE exempt structures, sequence the parent and subsidiary applications, and align the filing with the United Kingdom and Ireland position, so that the status is claimed in time and holds up when it is tested. This note is general information, not advice on your own facts, so confirm your position before you rely on it. ## Glossary concepts in this article - [Holding Company](https://www.boruconsulting.com/glossary/holding-company): A company whose main purpose is to own shares in other companies rather than trade in its own right. - [Abu Dhabi Global Market (ADGM)](https://www.boruconsulting.com/glossary/adgm): A financial free zone in Abu Dhabi that applies English common law directly and has its own courts and financial regulator. - [Dubai International Financial Centre (DIFC)](https://www.boruconsulting.com/glossary/dubai-international-financial-centre): A financial free zone in Dubai with its own common-law courts and independent regulator, running a legal system separate from the wider UAE onshore framework. --- Source: https://www.boruconsulting.com/blog/fta-decision-15-2026-exemption-deadlines