عربي
Home Accounting Accounting & BookKeeping Auditing UAE TAX Consultant Report Business Support Governance & Compliance Updated & News About Us ☰
Home Accounting Accounting & BookKeeping Auditing UAE TAX Consultant Report Business Support Governance & Compliance Updated & News About Us



QFZP Distribution Agreed-Upon Procedures Report

FTA Decision No. 6 of 2026 and agreed-upon procedures for a Qualifying Free Zone Person

Federal Tax Authority Decision No. 6 of 2026

The Decision introduces additional compliance procedures for a specific category of Qualifying Free Zone Persons: those carrying on the Qualifying Activity of distributing goods or materials in or from a Designated Zone for UAE Corporate Tax purposes.

Its central requirement is a separate agreed-upon procedures report prepared by an independent external auditor licensed in the UAE in accordance with International Standard on Related Services ISRS 4400, in addition to the annual audit of the financial statements.

The report does not merely review accounting figures. It performs and documents specific procedures to verify customer reseller status and, where the goods enter the UAE and are imported by the Qualifying Free Zone Person, importation through a Designated Zone.

The Decision applies to Tax Periods commencing on or after 1 January 2026. Affected businesses should therefore organise the required evidence from the beginning of the Tax Period rather than waiting until the report becomes due.

This requirement does not apply to every Free Zone company. It applies to a Qualifying Free Zone Person relying on the Qualifying Activity of distribution of goods or materials in or from a Designated Zone.

Who Is Within the Scope of the Decision?

Qualifying Free Zone Person

The entity must first qualify as a Qualifying Free Zone Person and continue to satisfy the other conditions under the Corporate Tax Law and the related decisions.

Distribution of Goods or Materials

The Decision applies where the business relies on the Qualifying Activity involving the buying and selling of goods, materials, component parts or other tangible movable items.

In or From a Designated Zone

Being located in a Free Zone is not enough. The relevant activity must be carried on in or from an area formally recognised as a Designated Zone under the applicable legal instruments.

Important: A Free Zone licence does not automatically place a business within this Decision, and not every Free Zone is necessarily a Designated Zone for this Qualifying Activity.

What Is New Under FTA Decision No. 6 of 2026?

A Separate Report

A separate agreed-upon procedures report is now required in addition to the annual audited financial statements, even where the same auditor performs both engagements.

Mandatory Procedures

The Decision specifies the procedures to verify customer reseller status and to verify importation through a Designated Zone where the import condition applies.

Detailed Supporting Evidence

A business description or invoice alone is not sufficient. Customer licences, declarations, agreements, invoices, purchase orders, customs documents and shipping records are required.

Statutory Sample Formula

The Decision introduces a formula using a 10% margin of error and requires the sample to include the customers, agreements or imports with the highest transaction values.

A Separate Filing Deadline

The report must be submitted to the FTA no later than 30 days after the deadline for filing the Corporate Tax return for the relevant Tax Period, unless the FTA specifies another date.

Direct Effect on Eligibility

Failure to submit the report means the conditions connected with the distribution activity are not treated as satisfied, creating a serious risk to QFZP status.

Is the Report an Audit or Assurance Opinion?

An agreed-upon procedures report is not a replacement for the audit of the financial statements, and the auditor does not provide a general opinion that the business is compliant or that all transactions are correct. The auditor performs specified procedures and reports the factual findings arising from each procedure.

The report must be prepared in accordance with ISRS 4400 by an independent external auditor licensed in the UAE. It may be prepared by the auditor responsible for the annual financial statement audit or by another independent auditor licensed in the UAE.

The engagement requires documented procedures, specified samples, factual findings and an appendix containing details of the samples selected. It is more than simply compiling the company’s documents.

Evidence and Procedures for Verifying Customer Reseller Status

Customer Licences

Obtain valid trade, business or commercial licences or equivalent documents and inspect the listed activities for trading, wholesaling, retailing, distribution, manufacturing or other indicators of resale.

Written Customer Confirmations

Obtain a signed and dated declaration or written confirmation relating to the relevant Tax Period and confirming that the goods or materials are acquired for sale, resale, or processing or alteration for sale or resale.

Agreements and Transaction Records

Inspect executed sales agreements, related invoices, purchase orders and other records, and document indications of onward sale such as bulk quantities, resale terms or relevant pricing structures.

The evidence, taken together, should demonstrate that the customer resells the goods or materials, or parts thereof, or processes or alters them for the purpose of sale or resale. Supplies to a public benefit entity are also addressed under the related qualifying activity rules.

Evidence and Procedures for Importation Through a Designated Zone

Import and Customs Documentation

Inspect customs declarations, import permits, sales contracts, bills of lading and equivalent documents showing lawful entry of the goods into the UAE through a Designated Zone.

Confirmation of Designated Zone Status

Verify that the Free Zone, port or area identified in the import documents is formally recognised as a Designated Zone, supported by confirmation from the relevant Free Zone Authority.

Internal Goods Movement Records

Inspect inventory logs, warehousing reports, goods movement records and logistics documents to verify receipt, handling or storage within the Designated Zone before distribution.

The import procedures apply where goods or materials enter the UAE and are imported by the Qualifying Free Zone Person. The actual supply chain facts should be reviewed before determining the required procedures.

How Is the Sample Size Calculated?

The Decision defines a 10% Margin of Error and provides the following formula for determining the Sample Size from the Sample Population:

Sample Size = Sample Population ÷ [1 + (Sample Population × 0.10²)]
Sample Population Formula Result
109.09
5033.33
10050.00
50083.33
1,00090.91

The figures above are the direct mathematical results. The Decision does not expressly state how fractional results should be rounded to a whole number, so the rounding approach should be determined and documented with the auditor before sample selection.

The Sample Population depends on the procedure and may be the total number of customers, sales agreements or imports during the Tax Period. The selected sample must include the items with the highest transaction values in the relevant Tax Period.

When Must the Report Be Submitted?

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 another date is specified by the FTA.

Businesses should not wait until the Tax Period has ended. The report relies on customer licences, declarations, agreements, customs documents, shipping records, inventory data and goods movement evidence that may be difficult to reconstruct later.

What Happens If the Report Is Not Submitted?

The Decision states that failure to submit the report means the relevant conditions under the audited financial statements decision and the qualifying and excluded activities decision are not considered met.

Because continued QFZP status depends on satisfying the legal conditions, non-compliance may cause the entity to cease being a Qualifying Free Zone Person from the beginning of the relevant Tax Period, with possible consequences extending to the following four Tax Periods under the general QFZP rules.

Practical Preparation Plan

1Confirm the scope: Review the licence, actual activity, sales flow and import flow to determine whether the business carries on distribution in or from a Designated Zone.

2Update customer files: Maintain each customer’s licence, expiry date, licensed activities, reseller status and signed declaration for the relevant Tax Period.

3Link evidence to transactions: Connect each invoice, agreement and purchase order to the customer evidence supporting reseller status instead of keeping only general documents.

4Create an import file for each shipment: Include the customs declaration, import permit, bill of lading, receipt, warehousing and goods movement documents.

5Obtain Designated Zone confirmation: Retain evidence that the relevant port or area is legally recognised as a Designated Zone and obtain confirmation from the relevant authority where required.

6Prepare sample populations: Maintain complete customer, agreement and import listings with transaction values so the auditor can calculate and select the required samples.

7Engage the auditor early: Agree the engagement scope, procedures, required evidence, rounding approach and treatment of additional documents before the reporting deadline approaches.

8Perform a gap review: Identify customers, agreements or imports with missing or inconsistent evidence and address the gaps before the final report is prepared.

How Can Al Basma Help?

Applicability Review

Reviewing the activity, supply chain, customers and imports to identify whether the Decision applies and what evidence the company needs.

Supporting File Preparation

Organising customer licences, declarations, agreements, invoices, import and customs documents, inventory reports and goods movement records.

Sample Schedules

Preparing complete sample populations, transaction values and supporting schedules to assist the licensed auditor in performing and documenting the procedures.

Readiness Review

Performing a pre-review to identify missing, inconsistent or unlinked evidence that may affect the factual findings reported by the auditor.

Coordination With a Licensed Auditor

Preparing the accounts and supporting file and coordinating with the independent external auditor licensed in the UAE who issues the ISRS 4400 report.

Ongoing Process Improvement

Introducing internal procedures, templates and records to collect reseller and importation evidence continuously during each Tax Period.

Al Basma assists with reviewing, preparing and organising the supporting file and professional coordination. The agreed-upon procedures report itself must be issued by an independent external auditor licensed in the UAE.

Frequently Asked Questions

Is the report required for every Free Zone company?

No. It applies to a Qualifying Free Zone Person engaged in the Qualifying Activity of distributing goods or materials in or from a Designated Zone, subject to the related legal conditions.

Does the annual financial statement audit replace this report?

No. The Decision requires an additional agreed-upon procedures report. It may be prepared by the annual external auditor or by another independent auditor licensed in the UAE.

Is a customer reseller declaration by itself sufficient?

The declaration is important but it is not the only evidence. The procedures also inspect the customer licence, sales agreements, invoices, purchase orders and transaction records supporting actual resale or processing and alteration for sale or resale.

Must every customer and every import be inspected?

The Decision provides a sampling formula using a 10% Margin of Error and requires the highest-value items to be included. Nevertheless, the business should retain adequate documentation for all relevant transactions, not only the items later selected in the sample.

What are factual findings?

They are the actual results of each procedure, such as whether a licence was valid, a declaration was signed and dated, or customs and shipping documents showed entry through a Designated Zone. They do not constitute a general assurance opinion over the entire activity.

When does the Decision apply?

It applies to Tax Periods commencing on or after 1 January 2026. The Decision was issued on 2 June 2026 and published by the FTA within the Corporate Tax legislation section.

Official Legal Source

Federal Tax Authority Decision No. 6 of 2026: Determining the Additional Procedures for the Compliance of Qualifying Free Zone Persons Engaged in the Activity of Distribution of Goods or Materials in or from a Designated Zone for Corporate Tax purposes.

Federal Tax Authority Corporate Tax Legislation

This page provides general information and does not replace a review of the company’s actual facts, contracts, supply chain and supporting evidence. It is not itself an agreed-upon procedures report or an external auditor’s opinion.

Important Notice: The information provided on this page is intended for general informational purposes only and does not constitute legal, tax, accounting, or professional advice. It should not be relied upon as a substitute for reviewing the applicable laws, regulations, decisions, and official guidance issued by the competent authorities in the United Arab Emirates.

The appropriate legal, tax, or accounting treatment may vary depending on the specific facts and circumstances of each case.

If you require professional advice or assistance relating to your particular situation, please contact us and our team will be pleased to review your case and provide appropriate support.


Related Updates and Articles

site menu

Al Basma Accounting & Bookkeeping provides accounting, audit, taxation, financial advisory, expert reporting, and company formation services in the United Arab Emirates.
Al Basma is also an FTA Approved Tax Agency providing VAT, Corporate Tax, and Tax Compliance services in accordance with UAE tax regulations.

Our Services

```
Al Basma Services

Contacts

Call  +971506861518

Whatsapp: 00971525886295

EMAIL : info@albasmaa.com

Financial Solutions

 

Corporate Tax

To Know our Services, Don't wait call us or leave your Number in online Chat with time you can received our call and we will call you back or send Email to info@albasmaa.com  now.

For join for our team please to send C.V. for Waleed@albasmaa.com