UAE, 16 September, 2026: The UAE’s recognition of RAK International Corporate Centre (RAK ICC) as a Free Zone for Corporate Tax purposes is creating new structuring opportunities for private wealth and investment vehicles.

Under Cabinet Resolution No. 109 of 2026, RAK ICC was added to the UAE’s Free Zone list with retroactive effect from 1 June 2023, allowing eligible RAK ICC entities to potentially qualify as Qualifying Free Zone Persons (QFZPs).

Potential 0% Corporate Tax

A qualifying RAK ICC entity may benefit from the 0% Corporate Tax rate on Qualifying Income, subject to meeting the relevant QFZP conditions, including substance, audited financial statements, transfer pricing compliance and the applicable de minimis requirements.

The change is particularly relevant to personal investment companies, holding companies and SPVs holding shares and other securities for investment purposes.

Existing Structures Can Reassess

RAK ICC entities that previously paid Corporate Tax at 9% may review their tax positions from 1 June 2023 and assess whether amendments or potential refund claims are available.

The Family Foundation regime also remains available, creating two potential pathways tax transparency under the Family Foundation regime or QFZP treatment for eligible RAK ICC companies.

The appropriate treatment will depend on the entity, assets, income and applicable UAE Corporate Tax conditions.