According to Article 28 of the Federal Decree-Law No. 47 of 2022, expenditure is deductible if it is:

Incurred wholly and exclusively for the purposes of the Taxable Person’s Business

and

Not capital in nature.

In this case, payments to freelancers outside the UAE can be considered deductible expenses, provided that these expenses are directly related to generating taxable income for your business. It's important to ensure that:

Proper documentation is maintained, such as contracts and invoices, clearly showing the nature of services rendered and their necessity for your business operations.

Payments are recorded accurately in your financial statements as part of business expenses.

Article 28, Clause 1 specifically allows deductions for business-related expenses, while Clause 2 mentions that deductions are not allowed for expenditures that are:

Not incurred for the business purpose,

Incurred in deriving exempt income,

Or losses not connected with the business.

Best Practice for Inclusion in Corporate Tax (CT):

Classify these expenses under professional fees or consultancy charges in your financial statements.

Ensure all transactions are documented and can be linked to your business operations.

Including these expenses correctly will help in calculating the taxable income, on which the corporate tax will be applied as per Article 3 of the Decree-Law, with a standard rate of 9% on taxable income exceeding the specified threshold.