TITLE: UAE Tax and Compliance Checklist for September 2026: VAT, Free Zone and Corporate Tax Deadlines
Prepare for UAE VAT changes from 1 October 2026
Cabinet Decision No. 149 of 2026 amends the UAE VAT Executive Regulations. Most changes take effect on 1 October 2026. The revised input tax apportionment rules will apply from the first tax year beginning after 1 October 2027.
Review these areas now.
Reassess bundled products and services
Where a transaction contains multiple economically interconnected components that cannot reasonably be separated, it may be treated as one composite supply. VAT treatment will generally follow the principal component.
This matters if you sell:
- Product and installation packages.
- Subscription bundles.
- Digital services with support or implementation.
- Goods combined with delivery, configuration, or training.
Review your contracts, pricing and invoices. Separately listing components does not automatically make them separate supplies.
Monitor high-value cash payments
Input VAT may be restricted where:
- The supply exceeds a value set by the Minister of Finance; and
- The consideration is paid, or intended to be paid, in cash.
The threshold has not been set in Cabinet Decision No. 149 itself. Monitor further Ministry of Finance guidance and move high-value supplier payments to traceable non-cash methods wherever possible. This will protect potential input VAT recovery and strengthen your audit trail.
Update healthcare and medical product coding
The amendments consolidate pharmaceutical products and medical equipment into the broader category of medical products. Qualifying medical products may continue to receive zero-rating under the relevant Cabinet Decision.
If your digital business supplies healthcare products, software-connected equipment or medical fulfilment services, confirm the applicable product classification before issuing October invoices.
Document employee benefits correctly
The new rules revise input VAT recovery for goods and services provided to employees for personal benefit. They also clarify the treatment of accommodation and benefits connected with labour legislation, employment contracts and FTA-prescribed conditions.
Keep the following records together:
- Employment contracts.
- Written HR policies.
- Accommodation agreements.
- Evidence of any legal or regulatory requirement.
- VAT invoices and payment records.
Good documentation makes your recovery position easier to support.
Change capital asset and credit note procedures
For the Capital Asset Scheme, the definition now focuses on a business asset and its cost. The AED 5 million threshold, VAT requirement and useful-life conditions remain relevant.
Review your fixed asset register and identify assets that may fall within the scheme.
Also update your invoicing system. The words “Tax Credit Note” must be clearly displayed on the credit note itself. They should not appear only in the invoice wording or system description.
Plan for output-based input tax apportionment
Partially exempt businesses will move from the existing input-tax-based standard method to an output-based method. The calculation will generally refer to the value of supplies permitting input tax recovery compared with total supplies, subject to exclusions.
The revised method applies from the first tax year beginning after 1 October 2027. Start modelling the effect now if your business has taxable and exempt activities. This gives you time to improve transaction coding and residual input VAT reporting.
KPMG’s summary of Cabinet Decision No. 149 of 2026 provides further technical detail.
Use Dubai’s free zone mainland-access routes carefully
Dubai Executive Council Resolution No. 11 of 2025 allows eligible free zone establishments to conduct activities outside their free zone and within Dubai, subject to the required DET licence or permit.
Available routes include:
- A branch established within the Emirate.
- A branch operating out of the free zone.
- A temporary permit for specific activities.
A branch operating out of the free zone costs AED 10,000 per year under the Resolution. A temporary permit costs AED 5,000 and may be valid for up to six months.
The framework does not apply to financial establishments licensed in the DIFC.
Your business must also maintain separate financial records for mainland activities and free zone activities. This is particularly important for ecommerce groups selling through multiple channels.
Typical documents include:
- Free zone trade licence.
- Memorandum of Association.
- Passport and Emirates ID of the manager.
- Licensing authority approval.
- Board resolution and power of attorney, where applicable.
- Mainland lease documents, if a physical branch is required.
- Activity-specific approvals.
The original regularisation period began on 3 March 2025 and ran for one year. The Resolution permits a possible one-time extension. If your company was already operating on the Dubai mainland, confirm its current status with DET rather than relying on the original deadline.
Read the official Dubai legislation before applying.
Meet the 30 September Corporate Tax deadline
If your business had a 31 December 2025 year end, your UAE Corporate Tax return and payment are due by 30 September 2026 through EmaraTax.
The deadline applies even if:
- Your Corporate Tax liability is nil.
- You intend to claim Small Business Relief.
- Your business is newly operational.
- You have no tax to pay after deductions or adjustments.
The FTA confirms that businesses must retain supporting records, including transaction records, assets, liabilities and shares held. Records generally need to be retained for at least seven years.
The FTA’s Corporate Tax filing reminder confirms the nine-month filing rule and the 30 September 2026 example.
Check your EmaraTax shareholding disclosures
The 2026 EmaraTax return includes shareholding information covering, where relevant:
- Immediate parent company.
- Ultimate parent company.
- Parent-company tax residency.
- Multinational enterprise group details.
- TIN or TRN information where available.
Prepare an updated ownership chart before filing. Include corporate ownership, related-party relationships and changes during the tax period. If your company is owned directly by individuals, check how the current EmaraTax form re
