26 August 2026 · Recent Changes
What Changed in UAE Corporate Tax Filing
The Federal Tax Authority's 2026 legislation register lists FTA Decision No. 3 of 2024 on Corporate Tax registration timelines and FTA Decision No. 6 of 2026 on additional QFZP compliance procedures. Those decisions should be read with the Corporate Tax Law and current FTA return guidance before a filing position is finalised.
Exiloz Management & Tax Consultant · Dubai-based FTA-focused advisory · VAT, corporate tax & accounting
The new instruments do different jobs
Do not treat every item on the FTA legislation register as a new Corporate Tax return deadline. FTA Decision No. 4 of 2026 sets rules for maintaining accounting records and commercial books. It was issued on 2 June 2026 and is effective from 30 July 2026. FTA Decision No. 6 of 2026 adds procedures for a narrow QFZP distribution activity, while FTA Decision No. 12 of 2026 concerns registration and deregistration for top-up tax on multinational enterprises.
The object to refresh is different for each instrument. Decision No. 4 changes the form and access standard for records. Decision No. 6 changes the evidence file for a defined distribution activity in or from a Designated Zone. Decision No. 12 changes the registration, deregistration and notification file for entities within the top-up tax rules. The title of the decision is the first filter. The entity's activity is the second.
Example. A business has AED 50,000 of Payable Tax left unsettled for a full annual period. Under the amended penalty table, the annualized arithmetic is AED 50,000 x 14% = AED 7,000. The rule applies the 14% per annum penalty for each month or part of a month, so AED 7,000 is an illustration of a full-year rate, not a promise that every late balance will be charged exactly that amount.
- Name the decision and its issue or effective date.
- Identify the entity, activity and Tax Period it reaches.
- Assign an owner to the document that must change.
- Save the source copy used for the filing.
Match each decision to the business it reaches
FTA Decision No. 4 of 2026 applies to the information kept in accounting records and commercial books. It requires records to be complete, identical to the originals, clear and accessible to the FTA when requested. An electronic copy must include all pages in the same order, and partial scanning is not accepted. A third party may maintain the records, but the person remains legally responsible for their safety.
FTA Decision No. 6 of 2026 is narrower. It applies to a QFZP engaged in the qualifying distribution of goods or materials in or from a Designated Zone. The file must support reseller status and importation through the Designated Zone, and an independent external auditor prepares the agreed-upon procedures report. If your company is a service provider with no such distribution activity, do not build this report into the ordinary return pack.
FTA Decision No. 12 of 2026 is for entities subject to the top-up tax rules for multinational enterprises. It sets a registration application within seven months from the end of the first Fiscal Year in scope, with separate deregistration and notification rules. If your business is an ordinary UAE company outside those rules, start with the Corporate Tax filing instruments instead of copying a multinational group's checklist.
- Record-keeping decision: check originals, scans and access.
- QFZP decision: check distribution and Designated Zone facts.
- Top-up tax decision: check the MNE group position.
- Do not apply a narrow instrument to every taxpayer.
A change is useful only when it changes a document
A rule update is useful only when it changes a file someone can open. For Decision No. 4, compare the retained electronic copies with the original invoices, contracts and ledgers. Check that all pages are present, readable and retrievable. For Decision No. 6, put customer licences, signed reseller confirmations, invoices, sales agreements, customs declarations and shipping records in the QFZP folder. For Decision No. 12, identify the group entity and notification owner.
The FTA's current return guide should sit beside the legislation, not replace it. The guide says EmaraTax shows only fields and schedules that may apply to the Taxable Person. A new decision can change the supporting evidence without creating a new visible field. Record the source, the version date and the person who decided that a particular instrument did or did not apply.
This is the point where an old checklist becomes dangerous. A previous preparer may have stored a partial scan, treated a customer as a reseller without a licence, or filed a QFZP conclusion without the import trail. The right correction is to name the missing object and its owner. A note saying ‘review the latest rules’ does not tell anyone what to obtain.
- Put the source document beside the affected record.
- Name the person who owns the update.
- Keep a reason when an instrument is out of scope.
| Instrument | Who it reaches | Document to refresh |
|---|---|---|
| FTA Decision No. 4 of 2026 | Persons keeping tax records | Complete original or identical copy and access control |
| FTA Decision No. 6 of 2026 | QFZP distribution in or from a Designated Zone | Auditor procedures report and trade or import evidence |
| FTA Decision No. 12 of 2026 | Entities within top-up tax rules | Registration, deregistration and scope notifications |
| Cabinet Decision No. 129 of 2025 | Taxpayers with unsettled Payable Tax | Payment ledger and penalty calculation |
Use a change register instead of copying last year's pack
The mistake we see most is copying a previous checklist and changing only the return date. That misses the object that made the old conclusion true. Open the commercial licence, activity description, customer contracts, import file, ledger and retained record set. Then compare each object with the instrument that governs it. A changed rule should leave a visible mark in the working papers.
We recommend a one-page change register for every return. List the source title, publication or effective date, entity or activity affected, document checked, owner and conclusion. The reason is simple: a reviewer can test a short register against the file, while a long folder of unsorted PDFs hides which rule was applied. The register is a control, not a replacement for the source.
The evidence boundary is also real. The FTA's Corporate Tax Returns Guide says it is general guidance, not detailed technical guidance for every case, and is subject to change without notice. The English PDF for FTA Decision No. 6 of 2026 is marked as an unofficial translation. If a disputed phrase changes the filing position, preserve the facts, flag the translation issue and obtain a specific interpretation before submission.
- Check the rule against the actual business activity.
- Record the source date and document owner.
- Flag a translation or interpretation issue plainly.
A new penalty rule changes the closing conversation
Cabinet Decision No. 129 of 2025 amended the administrative penalty regime and took effect on 14 April 2026. The FTA says the unpaid Corporate Tax penalty is charged at 14% per annum for each month or part of a month on the unsettled Payable Tax, starting the day after payment is due. A change register should therefore show the due date, amount outstanding and source used for the calculation.
Example. If AED 50,000 of Payable Tax remains unsettled for a full year, the annualised arithmetic is AED 50,000 x 14% = AED 7,000. That is an illustration of the annual rate. The Decision applies the penalty by month or part of a month, so the working paper must use the actual due date and payment history rather than treat AED 7,000 as a universal charge.
The practical response is to separate three questions in the closing file: which instrument governs, which date starts the obligation and which document proves the balance. Use Cabinet Decision No. 129 of 2025 for the penalty rule, FTA Decision No. 4 of 2026 for retained record quality, and FTA Decision No. 12 of 2026 only where the entity is in scope for top-up tax. A copied checklist will not make those scope decisions.
- Record the effective date beside the changed rule.
- Calculate from the actual due date and payment history.
- Keep top-up tax requirements separate from ordinary filing work.
Frequently Asked Questions
For checking whether your workings are current.
Which 2026 decisions affect Corporate Tax filing?
The Federal Tax Authority's legislation register lists FTA Decision No. 3 of 2024 on Corporate Tax registration timelines and FTA Decision No. 6 of 2026 on additional compliance procedures for Qualifying Free Zone Persons. Read each decision with the current return guidance.
Does every new decision change the deadline?
The Federal Tax Authority's register lists instruments and publication dates, but that listing does not say every decision replaces the general return deadline. Read the operative text and current return guide, then confirm the filing date shown for the entity in EmaraTax.
How should a business monitor filing changes?
The Federal Tax Authority publishes legislation, guides and clarifications through its Corporate Tax pages. Check those sources before each return and whenever the entity profile changes, then save the source and version used for the filing workings.
Can Exiloz review a changed filing position?
The Federal Tax Authority requires a complete and accurate Corporate Tax filing. Exiloz can compare the entity profile and tax workings with the current FTA decisions and return guidance, then give your authorised filer a documented list of changes to consider.
Are your workings current?
Exiloz checks the applicable FTA decisions against your entity profile and filing workings before submission.