FTA issues summary of Private Clarifications issued up to May 2026

The United Arab Emirates (UAE) Federal Tax Authority (FTA) has released a compilation of Corporate Tax (CT) Private Clarifications issued up to May 2026. The document provides a consolidated overview of FTA's positions on a wide range of CT matters and serves as a useful reference for taxpayers seeking insight into the Authority's interpretation of the CT framework.

Private Clarifications are issued in response to specific taxpayer requests and are applicable only to the applicant and in respect of the facts presented in the application. Nevertheless, the publication of a consolidated summary provides valuable visibility into the FTA's current administrative approach and its interpretation of various aspects of the CT regime.

The clarifications cover a broad range of topics, including exempt persons, free zone taxation, qualifying activities, substance requirements, taxable income, participation exemption, tax groups, loss utilization, registration requirements, financial statements, tax periods, and transitional relief provisions. Through these clarifications, the FTA has provided additional guidance on the practical application of the CT Law and related implementing decisions.

While the clarifications do not constitute legislation and should not be regarded as generally binding guidance, they offer useful insight into the FTA's interpretative position on a variety of technical and operational matters.

Taxpayers should review the clarifications carefully to assess whether any existing structures, compliance positions, or CT filings may require reconsideration or if they need to obtain a formal and specific private clarification from FTA for their own facts.