The FTA has compiled dozens of Corporate Tax private clarifications into a single document. It’s essentially a ready-made guide to how the authority interprets the law in practice. There are no new rules in it, but there’s something far more useful: insight into how the FTA will look at your specific situation.
Why this document is worth reading
Corporate Tax legislation is written in fairly broad strokes, and in practice businesses run into plenty of questions: how should a specific transaction be treated, does a relief apply, does something need to be declared differently. Previously, the only way to get an answer to such questions was through a paid private clarification request. Now the FTA has compiled its key positions covering free zone companies, multinational groups, investment funds, family offices, logistics, partnerships, and financial institutions. The document’s core message: economic substance matters more than legal form. The FTA repeatedly emphasizes that tax consequences depend on what you actually do and can substantiate, not how it’s documented on paper.
A few takeaways relevant to small and medium businesses
- A permanent establishment doesn’t arise automatically. Simply holding a UAE trade licence doesn’t in itself create a Permanent Establishment for a foreign company. The FTA assesses each case individually, based on actual activity
- Transfer of tax losses between companies. The 75% common ownership condition can be satisfied through beneficial ownership, not only through legal structure
- REIT investors are taxed only on distributed income, not on unrealized gains in value
If your company is structured through holding entities, partnerships, or has international beneficiaries, it’s worth checking this document separately.
New requirement for QFZPs: audit for distributors in Designated Zones
Separately, the FTA issued Decision No. 6 of 2026, which is not a clarification but a new obligation. If your company is a Qualifying Free Zone Person and distributes goods from a Designated Zone, you’ll now need a report from an independent external auditor on Agreed-Upon Procedures (AUP). This means it’s no longer enough to simply meet QFZP criteria on paper; you need to be ready to support that with a formal audit opinion. Companies that fall into this category should clarify the requirements now, rather than waiting until the reporting period.
If you want to request a private clarification yourself
An important practical point: the FTA states clearly that it will reject a request if it’s hypothetical, incomplete, framed as a general request to confirm eligibility for a relief, or relates to a matter already addressed in the published guide. It’s also paid: AED 1,500 for a request relating to a single tax, and AED 2,250 if it relates to more than one tax. Before submitting a request, it’s worth checking whether your question has already been answered in the new compilation.
How to apply this to your business
Updates like this rarely require immediate action, but they do change how you should prepare your 2025 CT return (due September 30) and how you structure operations going forward. This is especially true if you have a free zone company, an international structure, or related-party transactions.
If you’d like to check whether these updates affect you, QFZP status, ownership structure, or clarification specific to your situation, book a free 15-minute consultation with Aizhan Uzakova: +971509174775.
