26 August 2026 · Evidence
What to Put in the First-Return File
The Federal Tax Authority's Corporate Tax filing guidance points taxpayers toward commercial licence information, financial records and business activity details before a return is prepared. A useful first-return pack also ties the trial balance to bank records, major invoices, contracts and tax adjustments. The FTA expects complete and accurate information, so keep the support with the working papers rather than only the submitted form.
Exiloz Management & Tax Consultant · Dubai-based FTA-focused advisory · VAT, corporate tax & accounting
The evidence pack is the bridge to the return
An evidence pack is the bridge between the ledger and the return. The FTA expects the information in a Corporate Tax return to be complete and accurate, and its records reminder names transaction records, asset records, liability records and share records as material support. Start with the source records for the Tax Period, then build the computation from them. A licence copy alone is not a file.
The FTA's August 2025 reminder says Taxable Persons and Exempt Persons must retain relevant records for at least seven years after the end of the Tax Period to which they relate. Cabinet Decision No. 74 of 2023 also sets record-keeping periods and extra periods for disputes, audits and certain voluntary disclosures. Use the longer practical retention rule in your internal file policy.
Do this before a preparer asks for documents. Export the trial balance and general ledger, close the bank reconciliation, collect material invoices and contracts, and write down every adjustment you expect to make. We recommend one folder per Tax Period because it is easier to find one missing contract there than inside a general company drive.
The business model determines the supporting records
The pack changes with the business. A service company needs contracts, invoices, time records and bank evidence for revenue and costs. A trading company may also need inventory, import, shipping and customer records. A business holding property needs property records kept with extra care. The FTA's list is a starting point, not a promise that every company can use the same checklist.
Small or loss-making does not mean record-light. The return still needs a path from accounting profit or loss to Taxable Income, even where the final tax is zero or a relief election is made. If the owner has paid expenses personally, or the company has paid an owner, director or related party, collect the agreement, invoice, approval and proof of business purpose before deciding the treatment.
The mistake we see most is sending a bank statement and calling it bookkeeping support. A bank statement shows movement, not why a payment was deductible, who received it, or which Tax Period owns it. Match the statement to the ledger, then match the ledger to the source document. The missing middle is where first-return adjustments usually hide.
Index the documents that make the number defensible
Your deliverable should be more than a zipped document dump. Build an index that names each file, period, transaction or balance it supports, and the person who supplied it. Add a reconciliation from the trial balance to the financial statements, then a separate bridge from accounting profit or loss to Taxable Income. Mark missing evidence plainly.
Retain the records that explain both the number and the judgement. That includes fixed-asset and loan schedules where relevant, inventory movement, major customer and supplier contracts, related-party support, payroll evidence, and papers for elections or relief. The FTA's Corporate Tax returns guide explains that free-zone schedules can require revenue, substance and qualifying-income information, so do not hide that work inside a generic folder.
An evidence pack also needs exclusions. It does not turn a consultant into a statutory auditor, certify books that were never prepared, or replace records the company cannot produce. Exiloz can organise and review the file, but the owner remains responsible for the accuracy of the information supplied and for retaining the underlying records.
Trace the return backwards to the source document
First, freeze the period. Save the final trial balance, general ledger, bank reconciliation and financial statements used for the computation. Second, trace large or unusual entries to contracts, invoices, payment evidence and approvals. Third, write each tax adjustment beside its amount and reason. A reviewer should be able to start with the return line and walk backwards to the document.
Fourth, resolve gaps instead of covering them with a guess. Ask the owner for the missing contract, invoice, import record or explanation, then mark the item as pending if it cannot be recovered. Fifth, run a tie-out: total revenue to sales records, cash to bank, liabilities to schedules and the tax bridge to the final return. Sign off the unresolved list before submission.
One arithmetic check shows why this order matters. Illustration: accounting profit is AED 500,000 and documented adjustments reduce it by AED 125,000. The bridge is AED 500,000 - AED 125,000 = AED 375,000. Under Cabinet Decision No. 116 of 2022, AED 375,000 at 0% produces AED 0 Corporate Tax before any other adjustment or credit.
A full folder is not proof unless it explains the tax
The cost of weak records is not limited to a delayed review. An unexplained adjustment can increase Taxable Income, a missing transaction can distort the return, and a file that cannot be produced later can make the company spend twice on reconstruction. The FTA reminder is direct about keeping records that support the information provided in returns. Keep the evidence with the computation.
Use a short evidence index as proof of work. It should show the record, the period, the ledger line, the tax question and the status. If a document is unavailable, say why, name the replacement evidence and state who must obtain it. Do not label an assumption as confirmed. That distinction matters if the FTA asks how the return was built.
The unresolved point is the exact support needed for an unusual transaction. The FTA guide explains the record duty, but it does not specify one universal document for every business model or contract. State that boundary in the working paper. A specific gap is manageable. A folder that looks full but cannot explain the tax number is not.
| Record group | What it proves | Minimum handling |
|---|---|---|
| Entity file | Legal name, licence, ownership and Tax Registration Number | Keep with the Tax Period index |
| Books and reconciliations | Accounting profit or loss and movement to the return | Tie totals to the general ledger and bank |
| Transaction support | Revenue, costs, assets, liabilities and related-party treatment | Link material entries to source records |
| Tax bridge | Adjustments, elections, relief and Taxable Income | Show amount, reason and evidence |
| Retention file | Records available for later FTA review | Follow the FTA's at least seven-year reminder |
Frequently Asked Questions
For building a supportable first-return file.
What records does the FTA expect?
The Federal Tax Authority says taxpayers should prepare the documents needed for the Corporate Tax return, including commercial licences, financial records and business activity details. The exact pack depends on the entity and its transactions. Add reconciliations and support for material adjustments so the return can be checked against the underlying books.
Do I upload every invoice with the return?
Not necessarily. The FTA filing process requires the return information and supporting documents where the service asks for them, while the business must retain records that support its position. Keep invoices, contracts and schedules organised for the relevant Tax Period, even when they are not all attached to the submission.
What proves an adjustment?
An adjustment is easier to defend when the working paper shows the accounting entry, the tax treatment, the calculation and the source record. The Federal Tax Authority's Corporate Tax guidance expects complete and accurate information. Keep the contract, invoice, reconciliation or policy note that explains why the tax number differs from the accounts.
Can Exiloz assemble the file?
Yes. Exiloz can organise the entity records, reconcile the accounting information and list the evidence still missing before the first return is reviewed. The work is filing support and tax review. The Federal Tax Authority remains responsible for the official return service and the legal requirements.
Do your records tie out?
Exiloz builds a first-return evidence pack from your records and flags gaps before the tax computation is reviewed.