The Federal Tax Authority has published a consolidated summary of the positions taken in private clarifications on exempt persons, permanent establishment, free zone qualification, participation exemption, taxable income adjustments and loss transfer. It is not new law, but it shows how the authority reads the borderline cases.
What happened
The Federal Tax Authority (FTA) has published a consolidated summary of the positions it has taken in private clarifications — binding rulings issued to individual taxpayers on their own facts — up to May 2026. The collection covers exempt persons, permanent establishment, free zone qualification, the participation exemption, adjustments to taxable income and the transfer of tax losses, across scenarios involving free zones, multinational groups, foreign investors, investment funds, family offices, logistics, partnerships, shipping and financial services.
What changes in practice
No new obligation arises. What changes is visibility: the document shows how the FTA reads the legislation in the borderline cases where the statute itself is silent or ambiguous, which is precisely where structuring decisions are made.
Who it applies to
Complex structures rather than single trading entities: cross-border groups with a UAE presence, holding companies, family offices, investment funds, and any arrangement where a permanent establishment question or a free zone qualification question is live.
The exposure
Building or maintaining a structure on an interpretation that the FTA has already rejected in a published clarification. The positions are not binding on third parties, but a structure that runs contrary to a stated FTA reading is unlikely to survive review, and the cost of unwinding it after the fact substantially exceeds the cost of checking now.
What to do now
Read the consolidated document against the group's existing structures rather than in the abstract, focusing on the clarifications that touch permanent establishment and free zone qualification. Where an existing structure relies on an interpretation that the collection contradicts, document the position and take advice before the next filing rather than after.
Sources
Published 16 August 2026 on the basis of public sources and official United Arab Emirates instruments. This is not legal or tax advice. Verify your position with a qualified professional before acting.