01
Document overview
The principal qualifying-income instrument for the 0% QFZP regime, covering permanent establishments, qualifying IP, de minimis, immovable property and substance.
- Effective from 1 June 2023.
- Read with Decision 229/2025.
- Decision 55/2023 is repealed.
02
Scope and exclusions
Applies to
Applies to qualifying free zone persons for tax periods beginning on or after 1 June 2023.
Limitations and exclusions
It does not grant 0% automatically: the CT Law conditions, qualifying/excluded activity lists, de minimis, substance, transfer pricing and audited-financial-statement requirements must all be met; Decision 55/2023 is repealed.
05
Official primary source
Cabinet Decision No. 100 of 2023
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