UAE Free-Zone Tax Benefits Now Face an Evidence Test Under FTA Decision No. 6 of 2026

The UAE has moved a free-zone tax condition into an evidence test.

FTA Decision No. 6 of 2026 requires certain Qualifying Free Zone Persons to obtain an independent agreed-upon procedures report.

The rule applies to businesses distributing goods or materials in or from a Designated Zone. It applies to tax periods beginning on 1 January 2026.

Deloitte reports that the auditor must test two points. Are customers buying for resale, onward supply, or processing for sale? Did goods entering the UAE come through a Designated Zone?

The report follows ISRS 4400. The FTA has also prescribed the sampling approach. It must be filed within 30 days after the corporate-tax return deadline.

This is a narrow rule. Its lesson is wider.

A preferential tax position only works when the operating record can support it. The entity chart, customs trail, customer evidence, contracts, invoices, and audit file must describe the same business.

For CFOs and holding-company owners, the work starts before year-end.

Map the qualifying activity to the actual transaction flow.

Test whether records sit with the right operating teams.

Give the auditor enough time to find exceptions before filing.

Does your tax structure survive an independent review of how the business actually trades?