Tax, Accounting & Compliance

The UAE anti abuse rule under Article 50 of the UAE Corporate Tax Law gives the Federal Tax Authority (FTA) broad powers to challenge artificial tax arrangements that lack genuine commercial substance. As UAE corporate tax enforcement intensifies in 2026, the General Anti-Abuse Rule (GAAR) is becoming a major focus area during FTA audits and tax reviews.
The rule targets arrangements designed mainly to obtain a tax advantage, including artificial business splitting, intercompany profit shifting, and structures created only to access corporate tax reliefs or exemptions. Businesses operating in the UAE should now ensure that every part of their structure has clear commercial rationale, genuine economic activity, and proper documentation.

A UAE FTA voluntary disclosure allows businesses to correct tax errors before the Federal Tax Authority discovers them during an audit. In 2026, voluntary disclosure has become far more important due to rising FTA inspections, active Corporate Tax audits, and the revised penalty rules introduced under Cabinet Decision No. 129 of 2025.
Businesses that identify and correct mistakes early can often reduce penalties, limit interest exposure, and improve their audit position. Once the FTA issues an audit notification for a specific tax period, the opportunity for lower-cost correction may no longer be available.

The UAE tax enforcement landscape is changing rapidly in 2026. The Federal Tax Authority (FTA) significantly increased inspection activity in recent years, and new amendments under Federal Decree-Law No. 17 of 2025 have expanded its audit powers from 1 January 2026.
For most businesses, the standard audit limitation period remains five years. However, the FTA can now extend audits up to 15 years in cases involving tax evasion or failure to register. Businesses filing late refund claims may also face extended review periods. As Corporate Tax return cycles mature, many UAE companies are expected to experience their first FTA audits in 2025 and 2026.

The UAE has extended the deadline for businesses with annual revenue above AED 50 million to appoint an Accredited Service Provider (ASP) under the new UAE e-Invoicing framework. The new deadline is 30 October 2026, while the mandatory go-live date of 1 January 2027 remains unchanged.
This gives businesses more time to select the right provider, but not more time to delay implementation. Companies that postpone preparation may face serious operational risks, including ERP integration delays, invoice validation failures, and disruption to customer payments once mandatory UAE e-Invoicing rules take effect.

The UAE Domestic Minimum Top-Up Tax (DMTT) introduces a 15 percent minimum taxation framework for large multinational enterprise (MNE) groups operating in the UAE. The regime applies to groups with consolidated global revenue of at least EUR 750 million and aligns the UAE with the OECD Pillar Two global tax framework. Effective from financial years beginning on or after 1 January 2025, the rules create new compliance, reporting, and tax calculation obligations for affected businesses. This guide explains who falls within scope, how the DMTT is calculated, available relief mechanisms, filing timelines, and the implications for UAE free zone entities.

The UAE Federal Tax Authority issued CTP010 on 29 April 2026, clarifying who qualifies as a Director or Officer under UAE Corporate Tax law. Under Article 36, both are treated as Connected Persons meaning payments made to them must reflect arm’s length market value and may require disclosure in your annual tax return. This guide covers the full Director and Officer test, real FTA case studies, and a practical compliance checklist for UAE businesses, free zone entities, family offices, and holding structures.