If your business is a Qualifying Free Zone Person (QFZP) that distributes goods or materials in or from a Designated Zone, there is a new compliance step you cannot afford to miss. FTA Decision No. 6 of 2026 introduces an additional procedure — an independent Agreed-Upon Procedures (AUP) report — that you must file to keep your 0% Corporate Tax benefit intact. It applies to tax periods starting on or after 1 January 2026.
Download the official FTA Decision (PDF)
What has changed
Issued by the Federal Tax Authority on 2 June 2026 under the Corporate Tax Law (Federal Decree-Law No. 47 of 2022) and related decisions — Cabinet Decision No. 100 of 2023 and Ministerial Decisions No. 84 and No. 229 of 2025 — the decision sets out an additional procedure for one specific Qualifying Activity: the distribution of goods or materials in or from a Designated Zone. To keep treating income from that activity as Qualifying Income taxed at 0%, an affected QFZP must now obtain an AUP report.
Who must comply
Any Qualifying Free Zone Person engaged in the qualifying activity of distributing goods or materials in or from a Designated Zone. If that describes your business, the requirement applies from your first tax period beginning on or after 1 January 2026.
The report you now need
You must obtain an Agreed-Upon Procedures (AUP) report, prepared under the International Standard on Related Services (ISRS 4400) by your independent external auditor — either the auditor who audits your financial statements, or any other auditor licensed in the UAE. The report documents the procedures performed and the factual findings, and must demonstrate two things:
- Your customers are resellers — they resell the goods, or process or alter them, for the purpose of sale or resale; and
- Any goods you import into the UAE entered through a Designated Zone.
Documentation to prepare
To evidence reseller status:
- Customer trade, business or commercial licences showing trading, wholesaling, retailing, distributing or manufacturing activity;
- Signed customer declarations confirming the goods are acquired for sale or resale;
- Sales agreements, invoices and purchase orders that show onward supply — bulk quantities, resale pricing or resale terms.
To evidence importation through a Designated Zone:
- Import declarations and customs clearance documents evidencing lawful entry through a Designated Zone;
- Shipping documents — a bill of lading, airway bill or equivalent — clearly indicating entry through a Designated Zone;
- Written confirmation from the relevant Free Zone Authority that the port or area is a formally designated Designated Zone.
How the sampling works
The procedures are performed on a sample of transactions, weighted towards your highest-value customers and imports. The sample size is calculated as:
- Sample Size = Population ÷ [1 + (Population × 0.01)], applying a fixed 10% margin of error.
- Because the sample focuses on your largest transactions, your biggest customers and imports should be the best documented.
How to prepare
- Start AUP planning before the tax period ends — not after the return is filed.
- Build a customer-onboarding checklist that captures reseller evidence at the point of sale.
- Agree the sampling scope with your auditor early to avoid surprises.
- Get Designated Zone status confirmed in writing by the relevant Free Zone Authority.
- Note that any change to the standard AUP wording must be disclosed as an appendix to the report.
How Active Auditors can help
As UAE-licensed auditors, we prepare ISRS 4400 Agreed-Upon Procedures reports, help you assemble and test the reseller and importation documentation, plan the sampling, and file within the FTA’s deadline — protecting your QFZP status and your 0% Corporate Tax benefit. If you distribute goods in or from a Designated Zone, talk to us well before your tax period ends.