From clarification to verification: New UAE Corporate Tax requirements for Free Zone distributors

FTA Decision No. 6 of 2026 introduces a formal evidence and reporting framework for Qualifying Free Zone Persons engaged in the Qualifying Activity of distribution of goods or materials in or from a Designated Zone. Read alongside the FTA’s consolidated summary of private clarifications, the Decision marks a shift from explaining how the distribution conditions are interpreted to requiring supporting evidence to be subjected to independently performed procedures and reported factual findings.

Executive summary

The Federal Tax Authority (FTA) has published two Corporate Tax developments of particular relevance to Free Zone businesses, and especially to Qualifying Free Zone Persons engaged in distribution. The first is the Corporate Tax – Summary of FTA Private Clarifications issued up to May 2026, which consolidates the FTA’s views across a wide range of topics¹. The second is FTA Decision No. 6 of 2026, issued on 2 June 2026, which introduces mandatory agreed-upon procedures for Qualifying Free Zone Persons (QFZPs) engaged in the distribution of goods or materials in or from a Designated Zone, and which applies to Tax Periods commencing on or after 1 January 2026².

The two documents do not share the same legal status. The Summary is interpretative guidance reflecting the FTA’s administrative approach as expressed in applicant-specific clarifications; Decision No. 6 creates legally binding procedural obligations³. Read together, however, they tell a connected story. The Summary illustrates how the FTA interprets the substantive conditions for the Qualifying Activity of distribution, while the Decision prescribes a detailed evidential framework for demonstrating compliance with those conditions. The Decision therefore shifts the focus from understanding the substantive requirements to evidencing compliance through prescribed documentation and independently performed procedures.

For a QFZP carrying on the relevant distribution activity, it is no longer sufficient merely to characterize its activities as distribution. It must collect, maintain and retain adequate supporting documentation and obtain an agreed-upon procedures report prepared in accordance with ISRS 4400 that records the prescribed procedures and related factual findings supporting its compliance position.

How Decision No. 6 fits within the existing framework

Businesses may reasonably ask why this additional layer of compliance has appeared. FTA Decision No. 6 did not emerge in isolation; it forms part of the broader legislative and regulatory framework governing Qualifying Free Zone Persons.

The Corporate Tax Law establishes the QFZP regime, defines Qualifying Income and sets the principal conditions for QFZP status, while authorising further matters to be determined through implementing decisions. Cabinet Decision No. 100 of 2023 provides the principal framework for determining Qualifying Income and elaborates several conditions relevant to QFZPs, including adequate substance. Ministerial Decision No. 229 of 2025 defines the Qualifying Activities, including distribution of goods or materials in or from a Designated Zone. Ministerial Decision No. 84 of 2025 sets the current audited-financial-statements requirements and separately requires QFZPs engaged in that distribution activity to comply with any additional procedures prescribed by the FTA. FTA Decision No. 6 of 2026 gives effect to that requirement by specifying the AUP Report, the supporting-documentation obligations, the procedures to be performed and the applicable sampling methodology.

Decision No. 6 does not redefine the substantive scope of the Qualifying Activity of distribution, which is principally set out in Ministerial Decision No. 229 of 2025. Nor is the Decision best understood as implementing that Ministerial Decision alone. Article 2(8) provides that, if the AUP Report is not submitted, the additional-procedures requirement in Article 2(3) of Ministerial Decision No. 84 of 2025 and the condition relating to the Qualifying Activity identified in Article 2(1)(l) of Ministerial Decision No. 229 of 2025 are not considered to have been met.

Decision No. 6 is therefore best understood as the procedural link between the substantive distribution rules in Ministerial Decision No. 229 and the additional-procedures requirement in Ministerial Decision No. 84. It also gives formal, independently performed procedural effect to the due-diligence expectations reflected in the Summary.

More broadly, the Decision may indicate a shift in the FTA’s administration of the distribution activity within the Free Zone regime. The Summary discussed below primarily illustrates how the FTA has interpreted the substantive distribution conditions in private clarification responses. Decision No. 6 introduces a structured evidential mechanism requiring the relevant matters to be supported by adequate documentation and examined through procedures performed by an independent auditor. In practice, this moves compliance beyond legal analysis and into operational governance: from clarification of the rules to documented and independently examined factual support for the taxpayer’s position.

One possible explanation for the specific focus on distribution is that qualification often depends on matters outside the distributor’s own operations, including the customer’s intended use of the goods and whether it acts as a reseller or an end user. Those matters are fact-dependent and require more than legal characterisation alone, which may explain why contemporaneous supporting documentation and independently performed procedures are particularly important for this activity.

A broader view of the Corporate Tax framework

The consolidated Summary brings together positions previously expressed by the FTA in private clarification responses issued up to May 2026. While it offers valuable insight into the FTA’s interpretation of the legislation, businesses should read it alongside the legislation itself and the specific facts of their own operations. Private clarifications are issued for the benefit of the particular applicant and do not constitute legally binding guidance applicable to other taxpayers. While they provide useful insight into the FTA’s administrative interpretation, they should not be treated as binding precedents³.

For Free Zone businesses, the Summary addresses matters including the legal form required to qualify as a QFZP, the assessment of adequate substance, transactions with other Free Zone Persons, the distinction between Qualifying and Excluded Activities, the scope of distribution, logistics, treasury and financing activities, and the determination of Qualifying Income.

Distinguishing resellers from end users

The Summary distinguishes between customers that resell the goods or process or alter them for onward sale and customers that incorporate them into products, infrastructure or machinery that they retain and use in their own activities. Where goods are incorporated into products that are subsequently sold to third parties, the activity may still qualify as distribution, regardless of how much processing the customer undertakes. By contrast, where the customer incorporates the goods into infrastructure or machinery that it retains and uses to provide services, the customer is treated as the end user, and the activity in respect of that customer does not qualify as a Qualifying Activity of distribution⁵.

The distinction is easiest to see through an example. Consider two customers that buy steel from a QFZP carrying on the relevant distribution activity. Customer A uses the steel to manufacture machines that it then sells to third parties. In those circumstances, Customer A would not be treated as the end user merely because it processes the steel, and the customer-use condition for distribution may be satisfied, provided the remaining statutory requirements are met.

Customer B uses the same steel to construct a factory that it retains and operates in providing its own services. Customer B is therefore the end user, and the distribution activity in respect of that customer would not satisfy the relevant Qualifying Activity condition. The same steel, supplied on similar commercial terms, can therefore fall on either side of the reseller/end-user distinction depending on how the customer ultimately uses it.

Distributors need not buy from the manufacturer

Of particular relevance to distributors, the FTA indicates that goods need not be purchased directly from a manufacturer. They may be acquired from another distributor without preventing the subsequent activity from qualifying as distribution, provided the relevant statutory conditions are otherwise met⁴. The clarification confirms that qualification does not depend on purchasing directly from the manufacturer. The FTA’s position confirms that ordinary multi-tier distribution chains remain capable of falling within the Qualifying Activity, provided each distributor independently satisfies the applicable statutory conditions.

This is particularly important for regional trading businesses, where goods commonly pass through multiple distributors before reaching the final customer. The clarification confirms that such commercial structures are not, in themselves, inconsistent with the Qualifying Activity.

Pricing mechanism is not determinative

The FTA further indicates that the pricing mechanism agreed with a customer — whether cost-plus, fixed margin, commission — does not, by itself, determine whether the activity qualifies⁶; the substantive nature of the transaction and the customer’s intended use of the goods matter more than the formula used to calculate the price. Free Zone distributors are expected to undertake appropriate customer due diligence, including Know Your Customer (KYC) procedures and obtaining confirmations through contractual undertakings or similar arrangements demonstrating that the customer is not the end user⁶.

This clarification illustrates that the Summary places greater emphasis on commercial substance than on contractual form. Whether a distributor earns a fixed margin, a cost-plus return or a commission is not what determines qualification; the decisive question is whether the statutory conditions for the Qualifying Activity are in fact satisfied.

From substantive qualification to evidential compliance

The Summary and the Decision, read together, mark a distinction that is worth stating explicitly. The Summary is concerned with substantive questions — who is an end user, who is a reseller, what counts as processing, how pricing should be treated. The Decision is concerned with evidential questions — what license, declaration, agreement, invoice, warehouse record or customs document must be produced to show that the substantive tests have been met. FTA Decision No. 6 of 2026 gives procedural effect to the due-diligence expectations reflected in the Summary by prescribing the documentation to be maintained, the procedures to be performed by an independent auditor and the factual findings to be reported under an ISRS 4400 agreed-upon procedures engagement.

Not merely an audit requirement

Under Ministerial Decision No. 229 of 2025, distribution of goods or materials in or from a Designated Zone is a Qualifying Activity. It consists of the purchase, sale and distribution of tangible or movable goods and may include their importation, storage, inventory management, handling, transportation and exportation. The goods entering the State must be imported through a Designated Zone and must be supplied to a customer that resells, processes or alters them for sale or resale, or to a public benefit entity⁷.

Where a QFZP carries on this Qualifying Activity, FTA Decision No. 6 of 2026 requires it, for each relevant Tax Period, to obtain an agreed-upon procedures report prepared in accordance with ISRS 4400 (the AUP Report) from either the independent external auditor responsible for auditing its annual financial statements or another independent auditor licensed in the State. The engagement must be performed in accordance with International Standard on Related Services (ISRS) 4400, Agreed-Upon Procedures Engagements, as issued by the IAASB, together with the UAE legislation governing auditing practices⁸. Importantly, the Decision permits the engagement to be performed either by the independent external auditor responsible for the annual financial statements or by another independent auditor licensed in the State, giving businesses flexibility in scheduling and resourcing the work.

The AUP Report should not be understood as simply another audit deliverable sitting alongside the annual financial statements. It effectively forms part of the legislative conditions for QFZP treatment: if the AUP Report is not submitted within the prescribed period, Article 2(8) provides that the additional-procedures requirement in Article 2(3) of Ministerial Decision No. 84 of 2025 and the condition relating to the Qualifying Activity identified in Article 2(1)(l) of Ministerial Decision No. 229 of 2025 are not considered to have been met. Unlike audited financial statements, then, the AUP Report is not merely evidential in the ordinary sense — failure to submit it carries direct and substantive tax consequences because the legislation deems the underlying conditions unsatisfied.

The selection of ISRS 4400 as the applicable standard is significant because unlike an audit engagement, an agreed-upon procedures engagement does not require the auditor to express an opinion or any level of assurance; it results only in a factual findings report describing the procedures performed and what was observed. Practically, this changes the question the auditor is answering. The auditor is not asked whether the taxpayer is compliant; the auditor is asked only whether specified facts were observed — for example, whether a customer license was inspected and what it stated, or whether a declaration was signed and dated. The ultimate assessment of compliance, and the tax consequences that follow from it, remain with the FTA and the taxpayer, not with the auditor. This distinction is particularly important because readers familiar with audit opinions may incorrectly assume that the AUP Report provides assurance over compliance. It does not.

The AUP engagement addresses two principal matters: first, whether the goods or materials were supplied to customers that resell them, or process or alter them for sale or resale; and second, where the goods were imported into the State by the QFZP, that they entered through a Designated Zone. A single AUP Report may address both areas where both are relevant⁹.

The auditor is not engaged to determine whether the taxpayer satisfies the statutory requirements for QFZP treatment as a matter of law. Rather, the engagement is limited to performing the prescribed procedures and reporting the resulting factual findings, leaving the legal evaluation of those findings to the taxpayer and, ultimately, the FTA.

Verifying customer reseller status

The reseller-status assessment is not satisfied by a single standard declaration. The Decision requires the auditor to inspect samples across several categories of evidence.

Customer licenses. The auditor inspects valid trade, business or commercial licenses, or equivalent documents, to determine whether the customer’s licensed activities include trading, wholesaling, retailing, distribution, manufacturing or another activity indicative of resale¹⁰. Businesses should ensure customer license copies are current, complete and legible, valid during the relevant Tax Period, and consistent with the customer’s actual activities. A license is not conclusive of reseller status; it is one indicator among several, and readers should not assume that a trading license, by itself, establishes that a given customer is a reseller rather than an end user.

Written customer confirmations. Signed and dated declarations or written confirmations should establish that the customer acquired the goods or materials for sale or resale (including processing or alteration for that purpose), or for donation to a public benefit entity. The auditor’s procedures include inspecting whether the declarations affirm the customer’s reseller status, are signed and dated, and relate to the relevant Tax Period¹¹. In practice, a generic declaration obtained at onboarding may not suffice; the confirmation should reflect the relevant goods, commercial arrangement and intended use. Businesses should resist the temptation to rely on a single standard declaration for all customers: the agreed-upon procedures are performed by reference to sampled transactions, meaning businesses should ensure that declarations accurately reflect the customer’s commercial role and intended use during the relevant Tax Period.

Importantly, the Decision describes these categories of documentation as evidence that “may include” the listed documents, rather than prescribing an exhaustive list. Businesses may therefore be able to rely on equivalent documentary evidence, provided it demonstrates the relevant factual matters the Decision requires.

Agreements and transactional records. The auditor inspects executed sales agreements, invoices and other transaction-related records for indicators of onward sale or resale — for example, bulk quantities, resale conditions and applicable pricing structures¹². As a practical matter, a reseller declaration may be less persuasive where the contractual terms or trading pattern instead indicate that the customer is the ultimate consumer, so businesses should ensure the license, declaration, agreement, invoice and actual transaction tell a consistent story.

This represents a marked evolution from the due-diligence expectations described in the Summary. Where the Summary indicated that a distributor should obtain contractual confirmations or undertakings that the customer is not the end user⁶, the Decision requires that the matters supporting that due diligence be evidenced through documentation capable of independent examination under the prescribed agreed-upon procedures.

Because the auditor’s procedures require evidence that relates to the relevant Tax Period, businesses should review customer onboarding procedures now. Reseller status is easier to demonstrate if it is captured at the outset of the customer relationship — through an up-to-date license, a properly worded declaration and consistent contractual terms — than if it must be reconstructed retrospectively once the AUP engagement is under way.

In practice, businesses should expect the auditor to consider multiple sources of supporting documentation — including, where relevant, licenses, declarations, agreements, invoices, warehouse records, customs records and goods-movement records — as part of the prescribed procedures. Consistency across these sources is now almost as important as their completeness: where one document contradicts another, the auditor is left with a discrepancy that a single well-drafted declaration cannot resolve.

Demonstrating importation through a Designated Zone

Where the QFZP imports goods into the State, the AUP procedures require the auditor to examine whether the supporting documentation indicates that the goods entered through a Designated Zone. The auditor inspects samples of import documentation — which may include customs declarations and clearance documents, import permits, sales contracts, bills of lading, airway bills and equivalent transport documents — and inspects confirmation obtained by the QFZP from the relevant Free Zone authority that the relevant Free Zone, port or area is recognised as a Designated Zone under the applicable UAE legislation. The Decision indicates this recognition should be supported by confirmation obtained by the QFZP from the relevant Free Zone authority¹³.

The auditor must also inspect inventory logs, warehouse reports, goods-movement records, stock-receipt documentation and logistics records to determine whether they indicate that the goods were received, handled or stored within a Designated Zone before distribution¹⁴.

The business should therefore be able to show a coherent, traceable movement of goods from importation through receipt, storage, handling and onward distribution, and any differences between customs, shipping, warehouse and accounting records should be reconciled before the engagement begins.

As with the reseller-status procedures, no single document is likely to be determinative in isolation. The evidential value lies in the consistency of the import, logistics, warehouse and inventory records when considered together.

The 10% margin of error does not mean testing only 10%

The Decision prescribes the following sampling formula:

Sample Size = Sample Population ÷ [1 + Sample Population × (Margin of Error)²]

For this purpose, the margin of error is defined as 10%¹⁵. This does not permit the auditor simply to inspect 10% of the population; the sample size must be calculated using the formula. The applicable population depends on the procedure and may comprise the total number of customers, sales agreements or relevant imports. In addition, the sample must include the customers, agreements or imports with the highest transaction values during the relevant Tax Period¹⁶. It is worth being precise about what this means in practice: the formula is not applied once to a single combined population. The Decision expressly requires separate sampling populations for customers, sales agreements and imports in relation to the prescribed procedures, while permitting the taxpayer and the auditor to agree the sampling process for other categories of documentation, where agreed between the auditor and the taxpayer, so a business may need to run the calculation more than once²².

It combines a prescribed statistical sample, calculated by reference to the size of the relevant population, with a risk-based overlay that requires the highest-value customers, agreements or imports to be examined regardless of what the statistical formula alone would produce¹⁶. The effect is that a distributor cannot satisfy the sampling requirement by testing only its smallest or most straightforward transactions; the highest-value transactions must always be examined.

Businesses with large customer or import populations should ensure records can be categorised by customer, agreement and import, with transaction values readily available for sample selection.

Submission deadline

The AUP Report must be submitted to the FTA no later than 30 days following the deadline for filing the Corporate Tax Return for the relevant Tax Period, unless the FTA determines another date¹⁷.

This is a separate compliance deadline and should be entered expressly in the business’s Corporate Tax calendar. Teams should work backwards from the submission date to allow time to close and audit the financial statements, finalise the return, prepare the relevant populations, select samples, resolve documentary gaps, complete the procedures and submit the report.

Consequences of non-compliance

If the QFZP fails to submit the AUP Report within the prescribed period, Article 2(8) of FTA Decision No. 6 provides that the additional-procedures requirement in Article 2(3) of Ministerial Decision No. 84 of 2025 and the condition relating to the Qualifying Activity identified in Article 2(1)(l) of Ministerial Decision No. 229 of 2025 are not considered to have been met¹⁸. Because satisfying those conditions forms part of the statutory requirement for the QFZP treatment, failure to satisfy them means the person no longer qualifies as a QFZP for the relevant Tax Period and the following four Tax Periods, in accordance with Article 18 of the Corporate Tax Law¹⁹.

The consequences can be significant. Under the Corporate Tax Law, a QFZP is subject to 0% Corporate Tax on Qualifying Income and 9% Corporate Tax on Taxable Income that is not Qualifying Income²⁰.

Decision No. 6 illustrates that, within the QFZP regime, procedural compliance is no longer merely evidential. Compliance with the prescribed procedures has itself become a statutory condition for retaining the benefits of the regime.

A governance issue, not only a tax issue

Compliance with Decision No. 6 cannot be delivered by the tax function alone. Sales teams originate the customer relationship and the commercial terms; legal teams draft the contracts and declarations; procurement generates the purchase orders that the auditor specifically examines for indicators of resale; logistics and warehouse teams generate the movement records; customs and shipping documentation sits with the import function; and finance retains the invoices and accounting records against which everything must reconcile. Preparing a defensible AUP population therefore requires coordinated input across sales, legal, procurement, logistics, customs, warehouse, finance and compliance functions, working to a timetable set by the tax team but populated with records that those other functions hold and generate day to day.

An open question: how many exceptions are too many?

The Decision prescribes what procedures the auditor must perform and how the sample must be selected. It does not specify how the FTA will assess exceptions identified through the agreed-upon procedures, or whether isolated deficiencies — a missing declaration for one customer, an unreconciled shipment — will affect the availability of the regime as a whole, and it does not define materiality for this purpose. Until further guidance is issued, businesses should treat complete compliance across all relevant transactions, rather than a tolerable error rate, as the working standard.

A related and equally unresolved question concerns reliance on customer representations that later prove incorrect. A customer may sign a declaration that it will resell or process goods for onward sale, and subsequently retain those goods for its own use instead. It is not clear from the Decision whether this means the taxpayer has failed to meet the distribution condition, whether the auditor’s inspection and reporting of factual findings in relation to that declaration was itself sufficient, or whether the customer’s subsequent conduct would have Corporate Tax consequences for the distributor despite the declaration originally provided. While robust and documented due diligence will strengthen the taxpayer’s position, the legislation does not yet indicate whether good-faith reliance on an inaccurate customer declaration will be sufficient to protect QFZP status.

A practical implication: document governance, not new documents

In practical terms, many businesses may discover that they already possess most of the required documentation — licences, declarations, agreements, invoices, warehouse and customs records — but not in a manner that allows it to be readily reconciled across functions or matched to a specific customer, agreement or shipment for a specific Tax Period. The compliance challenge is therefore likely to be less about creating new documents than about establishing document governance capable of demonstrating a consistent audit trail.

Businesses should also avoid treating the AUP engagement as a year-end documentation exercise. Attempting to reconstruct customer status, shipment records or contractual evidence after the transactions have occurred is likely to be considerably more difficult, and less reliable, than embedding the required controls into normal business operations throughout the Tax Period.

What affected businesses should do now

QFZPs engaged in distribution should, before the end of their first affected Tax Period:

confirm which revenue streams fall within the Qualifying Activity of distribution and separate them from manufacturing, logistics and other activities;
identify whether customers act as resellers, processors for onward sale, public benefit entities or end users, taking particular care where goods are used in construction, infrastructure, machinery or services;
review and update customer onboarding procedures so that reseller status is captured at the start of the relationship rather than reconstructed later;
obtain valid customer licences and carefully drafted reseller declarations relating to the relevant Tax Period;
confirm that agreements, invoices, purchase orders and trading patterns support those declarations, and resolve any inconsistencies between them;
reconcile the customs, shipping, warehouse and goods-movement trail for imported goods;
prepare customer, agreement and import populations by transaction value so that the prescribed sampling methodology can be applied and the highest-value items identified;
agree the engagement timetable and information requirements with the auditor well ahead of the return deadline; and
allocate clear internal responsibility across tax, finance, sales, procurement, logistics, legal and compliance functions.

The Decision also signals a broader trend in UAE Corporate Tax administration. As the regime matures, the FTA appears increasingly willing to supplement substantive legislative rules with detailed procedural requirements designed to standardise compliance and facilitate verification. Whether similar evidential frameworks will emerge for other Qualifying Activities remains to be seen, but Decision No. 6 may provide an indication of the direction in which Free Zone compliance is evolving.

Conclusion

The consolidated Summary gives businesses a clearer picture of how the FTA has approached a wide range of Corporate Tax questions, while FTA Decision No. 6 of 2026 goes further by requiring certain Free Zone distributors to substantiate their position through prescribed documentation and independently performed agreed-upon procedures. The combined message is that Corporate Tax treatment must follow the commercial substance of the activity, and that substance must be supported by consistent, contemporaneous and auditable documentation.

The Decision could mark the beginning of a broader shift in the administration of the Free Zone regime. Rather than relying primarily on legal analysis of whether an activity qualifies, the FTA is increasingly requiring businesses to demonstrate qualification through contemporaneous operational evidence supported by prescribed agreed-upon procedures. The competitive advantage associated with Free Zone status will increasingly depend not only on meeting the legal conditions for Qualifying Income, but also on demonstrating those conditions through disciplined governance, contemporaneous record-keeping and cross-functional operational controls.

For Free Zone distributors, the immediate priority is to move beyond general customer confirmations toward a structured evidence framework covering customer status, intended use, contractual terms, transactional records, import documentation and the physical movement of goods. Early preparation will be critical to completing the AUP engagement within the prescribed timeframe and protecting QFZP status.

Footnotes

Federal Tax Authority, Corporate Tax – Summary of FTA Private Clarifications issued up to May 2026. The publication consolidates FTA positions across the topics listed in its contents, including exempt persons, permanent establishments, partnerships, Free Zones, participation exemption, deductions, losses, Tax Groups, financial statements and transitional relief. (Publication/issue date to be confirmed against the FTA website; the document as issued bears no printed date.) ↩
Federal Tax Authority Decision No. 6 of 2026, Determining the Additional Procedures for the Compliance of Qualifying Free Zone Persons Engaged in the Activity of Distribution of Goods or Materials in or from a Designated Zone, issued 2 June 2026; applies to Tax Periods commencing on or after 1 January 2026 (Art. 5) and comes into effect as of its date of issuance (Art. 6). (Any Official Gazette publication date to be confirmed against the FTA website.) ↩
On the status of clarifications, see Federal Decree-Law No. 47 of 2022, Art. 59 (Clarifications), under which a clarification is issued in respect of the applicant’s own proposed or completed transaction. Private clarifications are applicant-specific and are not formal decisions of the FTA; the Summary is interpretative guidance reflecting the FTA’s administrative approach, whereas Decision No. 6 creates legally binding procedural obligations. (Precise FTA clarifications-guidance reference to be confirmed before publication.) ↩ ↩
Federal Tax Authority, Summary of FTA Private Clarifications, “Free Zones – Qualifying Activities – distribution of goods or materials in or from a Designated Zone”, p. 11. ↩
Ibid., p. 11. ↩
Ibid., p. 12. ↩ ↩ ↩
Ministerial Decision No. 229 of 2025, Art. 2(1)(l) and Art. 2(3)(l). ↩
FTA Decision No. 6 of 2026, Art. 2(1)–(2). ↩
Ibid., Art. 2(3). ↩
Ibid., Art. 3(1)(a). ↩
Ibid., Art. 2(4)(b) and Art. 3(1)(b). ↩
Ibid., Art. 3(1)(c). ↩
Ibid., Art. 3(2)(a)–(b). ↩
Ibid., Art. 3(2)(c). ↩
Ibid., Art. 3(3)–(4). ↩
Ibid., Art. 3(1)–(2). ↩ ↩
Ibid., Art. 2(7). ↩
Ibid., Art. 2(8), which provides that the conditions in Ministerial Decision No. 84 of 2025, Art. 2(3), and Ministerial Decision No. 229 of 2025, Art. 2(1)(l), are deemed not to have been met. ↩
Ministerial Decision No. 229 of 2025, Art. 5(2), read with Art. 5(1)(b). ↩
Federal Decree-Law No. 47 of 2022, Art. 3(2). ↩
Cabinet Decision No. 100 of 2023 on the Determination of Qualifying Income for the Purposes of Federal Decree-Law No. 47 of 2022, in particular the provisions defining Qualifying Income and Excluded Activities and the conditions relating to adequate substance for Qualifying Free Zone Persons.
FTA Decision No. 6 of 2026, Art. 3(5). ↩

Disclaimer. This article is intended for general information only and does not constitute legal or tax advice. The application of the UAE Corporate Tax legislation depends on the specific facts and circumstances of each business, and readers should obtain specific advice before acting.

Asmae Bazaani
Counsel
[email protected]