Zona franca per le società negli Emirati Arabi Uniti: spiegazione delle norme AUP 2026

Corporate tax free zone UAE rules for distributors in or from a Designated Zone will require affected Qualifying Free Zone Persons to obtain and submit an Agreed-Upon Procedures report for tax periods starting on or after 1 January 2026. The key point is simple: if a free zone distributor relies on the distribution of goods or materials as a qualifying activity, it must be ready to prove customer reseller status, import routes through a Designated Zone, and the evidence checked by an independent UAE auditor.

What changed for Corporate tax free zone UAE in 2026?

The Federal Tax Authority has published FTA Decision No. 6 of 2026, which sets additional procedures for Qualifying Free Zone Persons engaged in the activity of distributing goods or materials in or from a Designated Zone. The rule is effective for tax periods starting on or after 1 January 2026.

Key points for affected businesses:

• The Qualifying Free Zone Person must obtain an Agreed-Upon Procedures report from the auditor of its annual financial statements or another independent auditor licensed in the UAE.
• The report must be prepared in accordance with ISRS 4400, Agreed-Upon Procedures Engagements, and applicable UAE audit legislation.
• The report must document the procedures performed and the factual findings, rather than giving a broad tax opinion.

For Corporate tax free zone UAE planning, this creates a practical evidence requirement. A distributor cannot only rely on the legal wording of the qualifying activity. It must be able to show that the relevant documents exist, match the transactions, and support the intended Corporate Tax treatment.

Who is affected by the new QFZP distribution rule?

The decision is aimed at Qualifying Free Zone Persons that claim the qualifying activity of distributing goods or materials in or from a Designated Zone. This is particularly relevant for trading, wholesale, logistics, commodity, and supply-chain businesses that use a free zone or designated customs location as part of their UAE structure.

For Corporate tax free zone UAE purposes, affected businesses should check whether:

• They supply goods or materials to customers that resell those goods or materials, or process or alter them for sale or resale.
• They import goods or materials into the UAE and need to prove that those goods entered through a Designated Zone.
• They rely on qualifying income treatment and need to preserve the basis for the 0% Corporate Tax rate on qualifying income.

A wider review of Qualifying Free Zone Person conditions may also be required. For background, WellTax has published an article for  Qualifying Free Zone Person UAE Corporate Tax changes, which discusses important updates to the UAE free zone corporate tax framework.

What evidence should businesses keep for the AUP report?

The new procedures are document-led. Businesses should not wait until the tax return filing stage to find customer declarations, customs papers, or logistics records. Evidence should be collected during the tax period, reviewed for consistency, and kept in a way that allows the auditor to test sample transactions efficiently.

Important evidence areas include:

• Customer records showing that the customer is a reseller or uses the goods or materials for onward sale or resale after processing or alteration.
• Import records showing that goods or materials entering the UAE were imported through a Designated Zone.
• Internal operational records showing that goods were received, handled, stored, or moved in a way that supports the documented import route.

AUP area	Documents to prepare	Practical purpose
Customer reseller status	Trade licenses, commercial licenses, written confirmations, signed declarations	Shows whether the customer’s activities are consistent with resale, distribution, trading, manufacturing, or similar activity
Transaction evidence	Sales agreements, invoices, purchase orders, pricing records, bulk order terms	Supports the commercial link between the goods supplied and resale or onward supply activity
Import through a Designated Zone	Import declarations, customs clearance documents, bills of lading, airway bills, import permits	Helps demonstrate that goods entering the UAE were imported through a Designated Zone
Designated Zone confirmation	Free zone or port confirmation, relevant legal designation records	Supports the auditor’s check that the identified area is formally treated as a Designated Zone
Internal movement records	Inventory logs, warehousing reports, goods movement records, logistics documentation	Shows that goods were received, handled, or stored within a Designated Zone before distribution

For businesses unsure whether a location is a Designated Zone for these purposes, WellTax’s guide to Zone Designate negli EAU provides additional context on designated locations and related tax considerations.

Corporate tax free zone UAE deadlines and non-compliance risk

The Agreed-Upon Procedures report must be submitted to the Federal Tax Authority no later than 30 days after the deadline for filing the Corporate Tax return for the relevant tax period, unless the Authority specifies another date. For calendar-year taxpayers within scope, the first affected tax period may be the year starting on 1 January 2026.

Three deadline points matter most:

• The trigger is the start of the relevant tax period, not the date on which the return is eventually filed.
• The AUP report timeline sits after the Corporate Tax return filing deadline, so it should be built into the annual compliance calendar.
• Failure to submit the report means the relevant conditions are not considered met for the distribution activity covered by the decision.

The last point is the main risk. If the AUP report is missing, the business may be unable to support the relevant qualifying activity condition for affected distribution income. Depending on the facts, this can affect the ability to rely on Qualifying Free Zone Person treatment and the 0% Corporate Tax rate for qualifying income.

How to prepare before the first affected tax period

The practical work should begin before year end. The sample testing rules mean the auditor will not necessarily review every transaction, but the sample must include the highest-value customers, sales agreements, or imports in the relevant tax period. That makes data quality and transaction tagging essential.

A preparation plan should include:

• Mapping customers, agreements, and imports by transaction value so the highest-value items can be identified quickly.
• Updating onboarding and sales processes so reseller confirmations and license checks are collected before or at the time of supply.
• Aligning the annual audit timetable, Corporate Tax return process, and AUP report timeline so the report is ready within the 30-day post-filing window.

WellTax can assist UAE free zone distributors with a practical readiness review, including customer evidence checks, document mapping, and coordination of UAE Corporate Tax compliance requirements before the first affected filing cycle.

How Corporate tax free zone UAE businesses should brief their auditors

The auditor’s work is factual and evidence-based. A clean briefing pack will help reduce delays and avoid unnecessary questions when the Agreed-Upon Procedures report is being prepared.

The pack should include:

• A complete sample population, such as total customers, sales agreements, or imports, depending on the procedure being tested.
• The highest-value transaction list for the relevant tax period, since those items must be included in the sample.
• Copies of customer licenses, declarations, invoices, import documents, Free Zone Authority confirmations, and internal logistics records.

The decision also includes a sample size formula:

Sample Size = Sample Population / [1 + (Sample Population × 10%^2)]

The margin of error is 10%. For documents outside the specific categories covered in the decision, the sampling process should be agreed between the Qualifying Free Zone Person and the auditor based on the requirements of the decision. Where the wording of a procedure is changed without changing its substance, the change should be included in an appendix to the report.

Final thoughts for UAE free zone distributors

Corporate tax free zone UAE compliance is becoming more evidence-focused for distributors in or from Designated Zones. The new AUP requirement does not replace the wider Qualifying Free Zone Person rules, but it adds a specific reporting step that affected businesses should plan for during the relevant tax period.

The best approach is to treat the AUP report as a year-round documentation process. Customer status, import route evidence, designated zone confirmations, and internal logistics records should be reviewed before the auditor asks for them. This is especially important for businesses with large customer volumes or high-value imports.

As an FTA registered tax agent in the UAE, WellTax can support businesses with UAE Corporate Tax compliance, document readiness, and communications with the Federal Tax Authority where relevant.

Scritto da Lorenzo Tosonotti, CIMA Dip Ma, Partner & FTA Tax Agent, WellTax.