If your business operates from a UAE Designated Zone and enjoys the 0% corporate tax rate on distribution income, there is a new rule you need to know about. The Federal Tax Authority has issued FTA Decision No. 6 of 2026, and it changes how you prove your right to the 0% rate. Here is everything at a glance.

The Decision at a glance

Two points that deserve special emphasis

Before going further, two aspects of this Decision stand out and are worth calling out clearly:

Where this comes from

Under Ministerial Decision No. 229 of 2025, distribution of goods or materials in or from a Designated Zone is a qualifying activity eligible for the 0% corporate tax rate. Two conditions sit at the heart of it:

• Reseller customers: your customers must be resellers, meaning they buy your goods for resale, or for processing or altering for the purpose of sale or resale, and
• Designated Zone importation: where you import goods or materials into the UAE, they must enter through a Designated Zone.

Until now, meeting these conditions was largely about keeping your own records in order. Decision No. 6 of 2026 changes that. The FTA now wants an independent auditor to test your evidence and report on what they find.

The new requirement: an agreed upon procedures report

• What you need: An agreed upon procedures report from an independent external auditor
• Who can prepare it: Your existing statutory auditor, or any other independent auditor licensed in the UAE
• The standard: ISRS 4400, the International Standard on Related Services for agreed upon procedures engagements, read with applicable UAE auditing legislation
• What it is not: This is not an audit opinion. The auditor performs procedures prescribed by the FTA and reports factual findings. The FTA draws its own conclusions from those findings

That last point matters. The strength of the findings depends almost entirely on the quality of the documents you can put in front of the auditor. Weak files mean weak findings, no matter how good your auditor is.

Remember that this sits on top of your existing obligations. The audited financial statements required for QFZP status still need to be prepared as before. The agreed upon procedures report is an extra layer, with its own deadline of 30 days from the corporate tax filing date.

Condition 1: Proving your customers are resellers

You need evidence that customers acquire your goods for resale or onward supply. Here is what to maintain and what each document must show:

Condition 2: Proving importation through a Designated Zone

Where you import goods or materials into the UAE, your evidence file should include:

What the auditor will actually do

The Decision prescribes the procedures in detail. In practice, expect the auditor to work through the following:

Each procedure in the report must describe the evidence obtained, when the work was performed, the extent of the work, and the factual finding. Sample details go into an appendix. If a procedure is reworded to fit your systems without changing its substance, that change must also be disclosed in an appendix.

How the sampling works

This is one of the most unusual features of the Decision. Under ISA and ISRS, sample sizes are normally a matter of the auditor’s professional judgement. Here, the FTA has fixed the methodology in the circular itself, and the auditor reports factual findings in the agreed upon procedures report based on the defined sample tested. The population may consist of customers, sales agreements, or import transactions for the tax period. The sample size equals the population divided by one plus the population multiplied by the square of the margin of error, with the margin of error set at 10%. In practice:

And here is the detail that matters most: the sample must include the customers, agreements, or imports with the highest values during the tax period. Your largest transactions will be examined first, so those files need to be the strongest.

Deadline, consequences, and who is caught

In short, this report is not a formality to be handled after everything else. It is the document that protects the tax benefit your free zone structure was built around.

An opening for auditors and advisors

There is another side to this Decision. It creates an entirely new engagement type in the UAE market:

• Recurring work: Every QFZP distributing from a Designated Zone needs an ISRS 4400 report, every year, prepared by a UAE licensed auditor
• New skills in demand: Testing the FTA defined sample, evidence review, and factual reporting under a prescribed framework
• Advisory scope: Documentation systems, readiness reviews before the auditor arrives, and reconciling import records with inventory and logistics data

For business owners, the practical takeaway is to involve your auditor early. An auditor appointed months before the deadline can flag missing declarations or gaps in customs paperwork while there is still time to fix them. One appointed at the last minute can only report what exists.

Your action checklist

• Confirm whether your business distributes goods or materials in or from a Designated Zone and claims the 0% rate on that income
• Map your customers and check you hold current licences and signed, dated declarations for them
• Pull your import files and verify customs declarations, bills of lading, and warehouse records line up and clearly show the Designated Zone
• Confirm with your Free Zone Authority that your zone holds Designated Zone status
• Identify your highest value customers and imports, since these will be sampled first
• Plan for both deliverables: the audited financial statements and the agreed upon procedures report
• Appoint and brief your auditor early, well before the filing deadline

The message behind FTA Decision No. 6 of 2026 is straightforward enough. The 0% rate remains available, but the days of simply asserting that conditions are met are over. From now on, you have to be able to prove it, with documents, on time, and through the eyes of an independent auditor.