A Free zone procurement company does not automatically receive a 0% Corporate tax rate.
To qualify as a Qualifying Free zone Person, the company must satisfy all applicable conditions, including:
The qualifying status of procurement, trading and distribution income depends on the exact activity, counterparties, location and movement of goods.
FTA guidance explains that the Free zone regime applies conditionally to Qualifying Income and that failure to meet the requirements can cause loss of qualifying status for the relevant and subsequent tax periods. FTA Guide on Free zone Persons
Distribution of goods or materials in or from a Designated Zone can be a Qualifying Activity where the detailed legal conditions are met.
The analysis can depend on matters such as:
A Free zone and a Designated Zone are not necessarily identical concepts for all tax purposes.
The company should obtain transaction-specific advice before modelling its profitability around a 0% rate.
A Dubai company providing procurement services must assess the IVA place-of-supply rules.
Questions include:
Where is the customer established?
Does the customer have a EAU fixed establishment?
Is the recipient a related company?
Is the service directly connected with goods or real estate?
Is the customer outside the EAU?
Does the customer receive the service outside the EAU?
Do any export-of-services conditions apply?
Is the hub acting as principal or disclosed agent?
Are costs being recharged?
Not every invoice to an overseas group company is automatically zero-rated.
The contractual recipient, actual beneficiary, establishment most closely related to the supply and nature of the service must be considered.
Where goods move from one foreign country directly to another without entering the EAU, the EAU IVA treatment requires analysis of the place-of-supply rules and the transaction chain.
The business should document:
Even when EAU IVA is not charged, the revenue may remain relevant for Corporate tax, accounting and potentially IVA-registration analysis.
Under EAU IVA law, the importer is generally the person named as importer for customs-clearance purposes. EAU IVA legislation
Incorrectly listing a customs broker, logistics provider or related company as importer can create IVA recovery and ownership problems.
Mandatory IVA registration generally applies where taxable supplies and imports exceed AED 375,000 under the applicable historical or expected-turnover tests.
An international procurement company should not assess registration based solely on its gross bank receipts. It must correctly classify:
Current registration information is available through the EAU Government IVA portal.
A company importing or exporting through Dubai generally needs the appropriate customs registration and business code.
Dubai Customs states that a licenza holder should obtain a Customs Business Code and submit the appropriate customs declaration using that code. It also confirms that a Free zone company selling goods into the mainland must process the relevant customs declaration. Dubai Customs FAQs
Customs registration should match:
Possible movements include:
The company should not use "re-export" as a general commercial label without confirming the correct declaration and documentary requirements.
Dubai Customs publishes a detailed service guide covering the available declaration categories and procedures. Dubai Customs Service Guide
The customs treatment depends on:
Although 5% is a commonly encountered customs-duty rate for many goods, different rates, exemptions and restrictions apply to particular categories.
The company should obtain a proper tariff classification instead of budgeting from a general percentage.
Accurate HS classification affects:
Supplier descriptions such as "components," "materials" or "accessories" may be insufficient.
Routing goods or invoices through Dubai does not automatically make the products EAU-origin.
Origin depends on the applicable rules, including whether sufficient production or transformation has occurred.
Repacking, relabelling or changing commercial documents may not create EAU origin.
Incorrect origin claims can result in:
Certificates of origin must reflect the applicable legal and documentary requirements.
The procurement hub should map every product to its regulator before shipment.
Approvazioni aggiuntive may apply to:
Dubai Customs notes that restricted goods may require approval from the competent authority before release. Dubai Customs guidance
A business engaged in importing, producing, stockpiling or releasing excise goods may have registration and reporting obligations.
The EAU Government identifies excise registration responsibilities for businesses importing or producing excise goods, among other specified cases. EAU Government Excise Tax guidance
The procurement hub should screen product categories before issuing purchase orders.
The company may use:
The agreement should define:
A third-party warehouse does not remove the company's responsibility for accurate inventory and customs records.
The hub should clarify the roles of:
The logistics contract should address:
Low freight rates can become expensive when detention, storage and clearance responsibilities are unclear.
Procurement hubs often have large cross-border payment flows, which can attract enhanced bank scrutiny.
Banks may request:
Trade-finance requirements may include:
No consultant or licensing authority can guarantee account or facility approval.
International procurement commonly involves:
The group should define:
The transfer-pricing model should reflect the entity controlling and bearing treasury risks.
A procurement hub dealing across multiple jurisdictions should implement risk-based screening.
Controls may include:
Screening only the named supplier is insufficient where intermediaries, shipping parties or ultimate users are involved.
Depending on its activities, the procurement hub may be subject to sector-specific AML obligations or enhanced scrutiny from banks and counterparties.
Risk indicators include:
The company should maintain clear documentary evidence for each transaction.
International purchasing teams face bribery and conflict-of-interest risks.
A procurement policy should cover:
Sensitive supplier appointments should not depend solely on one employee.
If the Dubai company purchases and resells goods, it may bear responsibility for product quality even where manufacturing is outsourced.
The company should establish:
Quality-control fees and inspection responsibilities should be built into the supply contracts.
A scalable procurement hub may need:
The system should preserve a reliable audit trail from purchase request through supplier payment and final delivery.
The company should implement controls for:
Procurement staff should not independently create a supplier, approve an order and release payment without appropriate separation of duties.
Audited accounts may be required by:
Even when not mandatory, an audit can be valuable for a procurement hub handling significant cross-border trade.
A service hub may need:
A trading and distribution hub may require:
A minimal flexi-desk may be unsuitable for an entity reporting substantial international trading revenue and controlling complex commercial risks.
An individual shareholder may commonly need:
A corporate shareholder may need: