A qualified executive who genuinely performs your substance in the UAE

No. Cabinet Decision 98 of 2024 amended Cabinet Decision 57 of 2020 so that Economic Substance Regulations apply only to financial years from 1 January 2019 to 31 December 2022. For any financial year ending after 31 December 2022 there is no ESR notification, no ESR report and no penalty exposure. Penalties already levied for those later periods were cancelled, and amounts already paid are refunded by the Federal Tax Authority. What applies now is the substance requirement inside the corporate tax regime.

A free zone business that meets the conditions set out in Federal Decree-Law 47 of 2022 and Cabinet Decision 100 of 2023, and therefore pays 0% corporate tax on its qualifying income instead of the standard 9%. Maintaining adequate substance in the free zone is one of those conditions.

Performing your core income-generating activities in the free zone, with adequate employees, assets and expenditure for the activity you run. There is no fixed headcount or spending threshold. Adequacy is judged against the nature and scale of what your business actually does, which is why a structure that works for a small holding company will not carry a trading or IP business.

Through corporate tax registration and the annual corporate tax return, not through a separate ESR-style filing. There is no standalone substance form to submit any more. The position is examined if and when the FTA reviews your return, which means the evidence needs to exist before a query arrives rather than being assembled after one.

A fractional engagement can work, provided it is real and properly documented. A QFZP can perform its core activities itself or through another party it genuinely supervises and controls. What matters is that the work happens in the free zone and the arrangement is evidenced. An executive on a documented retainer who actually does the work can support that. A name on a licence cannot.

It loses Qualifying Free Zone Person status, so its income is taxed at the standard 9% rate rather than 0%. Under the corporate tax rules that loss applies to the tax period concerned and the following four tax periods, so the cost compounds well beyond the year in question. Acting before an audit is usually far cheaper than managing the consequences afterwards.

Income from intellectual property carries the most demanding treatment, followed by fund management and financing activities. Pure holding structures carry the lightest burden, but only where they genuinely are passive. Once a holding company starts managing or administering its subsidiaries, the expectations rise with it.

Possibly, but only for financial years from 2019 to 2022. Those years were not cancelled and the FTA retains audit powers over them, so records for that period are still worth keeping. Anything from a financial year ending after 31 December 2022 carries no ESR exposure at all.

Typically employment contracts or service agreements, payroll records, minutes of the meetings where decisions were taken, activity records showing where the work was performed, evidence of premises, and records of expenditure. Our engagements are structured around maintaining this as the work happens rather than reconstructing it later.

In most cases we can match and deploy a qualified, UAE-based executive within weeks of the initial assessment. The timeline depends on your qualifying activity and how specialised the work is.

Our engagements typically run 30 to 60% less than a full-time executive appointment once salary, visa, benefits and recruitment fees are counted. The exact figure depends on scope, activity and documentation requirements.

In some cases, yes. It depends on the activities involved and how much work each entity genuinely requires. We assess this during scoping, because an executive spread too thinly across entities weakens every position rather than supporting them all.

Yes. We work with businesses across UAE free zones, and with mainland entities that have substance considerations tied to their corporate tax position.

Yes. If your business reaches a scale where a full-time appointment makes commercial sense, we can support that transition. Many engagements begin as fractional and evolve as the business grows.

We establish an evidence framework at the start of every engagement covering employment documentation, activity records, meeting minutes and expenditure logs. It is maintained throughout the engagement, so the position is defensible at any point rather than only at year end.