Tax Newsletter — June 2026

Corporate Tax

Corporate Tax Guide on Family Foundations (CTGFF1):

On June 10, 2026, the UAE Federal Tax Authority (FTA) released an updated Corporate Tax Guide on Family Foundations (CTGFF1). The updated guide builds on, and replaces, the first version issued in May 2025. While the core rules remain the same, this update introduces highly anticipated relief and clarity for family wealth structures.

Key Highlights:

LLCs don’t qualify directly as “similar entities”: For transparent status but can qualify indirectly under the multi-tier rules if wholly owned and controlled by an approved Family Foundation.

Joint ownership works: The FTA confirmed an underlying SPV or holding company keeps transparent treatment even if owned by multiple Family Foundations, provided every owner qualifies for transparency.

Arm’s length rules apply: Moving assets into a foundation must follow transfer pricing rules.

No step-up/step-down: Transitioning in or out of transparency doesn’t reset the asset’s Corporate Tax base cost – it carries over unchanged.

Family Offices stay taxable: Single-Family and Multi-Family Offices providing active management services remain fully subject to the 9% Corporate Tax.

The guide helps to assess for families whether their structures remain fit for purpose, aligned with FTA, and positioned to support long-term governance and succession objectives.

Corporate Tax Returns

For taxable persons with a financial year ending December 31, 2025, the deadline to file their first Corporate Tax return is September 30, 2026. June has seen a significant surge in advisory activity as businesses transition from impact assessments to trial filings.

Transfer Pricing scrutiny intensifying: The FTA is tightening its focus on Related Party and Connected Person transactions. Local Files and Master Files must be ready and meet the arm’s length principle particularly for management fees, intercompany loans, and cost-sharing arrangements.

Free Zone compliance pressure: The strict “Qualifying Income” criteria remain a key hurdle. Free Zone entities are reviewing non-qualifying revenue streams to avoid losing their 0% preferential tax status.

Value Added Tax

The UAE Federal Tax Authority has issued a new VAT Guide for the Education Sector, VATGED1, dated June 2026. The guide brings much-needed clarity to nurseries, schools, universities, and training centers. Zero-rating is applied strictly and narrowly.

To apply 0% VAT on core tuition and educational services, an institution must concurrently satisfy two strict pillars:

Institution Condition: Must be a Qualifying Educational Institution (QEI) recognized by the federal or local competent authority. Higher education institutions (universities/colleges) only qualify if they are government-owned or receive more than 50% of their annual funding directly from the government. Private universities failing this threshold are subject to standard 5% VAT.

The course must follow a qualifying curriculum formally approved by the competent federal or local educational authority.

The FTA draws a firm line on ancillary revenues. Mandatory uniforms, electronic devices, on-campus catering, and initial application fees for prospective students are all subject to the standard 5% VAT rate.

VAT Refunds for UAE Nationals Constructing New Residences:

The Federal Tax Authority (FTA) has launched a new initiative to expand the scope of expenses eligible for VAT refunds for UAE nationals constructing new residences, allowing citizens to claim refunds on an additional range of construction costs. This move aligns with the UAE leadership’s directives, coinciding with the Year of Family and supporting family growth and cohesion.

To qualify under the New Residences Refund Scheme (governed by Article 66 of the VAT Executive Regulation), the following criteria must be met:

Must be a natural person holding UAE nationality and valid digital Family Data.

Must be built on land owned/acquired by the applicant and used solely as a private residence for themselves or their immediate family. Commercial usage, leasing, or servicing (e.g., hotel apartments) strictly invalidates the claim.

To be considered a “residence,” the property must comprise at least cooking facilities, washroom/bathroom facilities, and sleeping quarters.

The FTA enforces tight statutory deadlines for applying the main VAT refund claim (Form VATGRH1). It must be submitted strictly within 12 months of the construction’s completion date.

KSA

E-Invoicing (Fatoora): Integration Phase Continues

Saudi Arabia’s ZATCA is continuing its wave-by-wave rollout of Phase 2 (the Integration Phase) of the Fatoora e-invoicing initiative. Unlike Phase 1, which only required businesses to generate structured e-invoices, Phase 2 mandates direct integration with ZATCA’s Fatoora platform for real-time clearance and reporting.

The latest wave: Wave 24 covers all taxpayers whose VAT-taxable revenue exceeded SAR 375,000 in 2022, 2023, or 2024, with an integration deadline of 30 June 2026. This is the lowest threshold to date, sweeping thousands of SMEs into mandatory Phase 2 scope. ZATCA gives each wave a minimum of six month’s notice before its go-live date. Integration isn’t a simple switch-on. Affected businesses must validate their XML formatting (UBL 2.1), cryptographic stamps (CSID), and UUID generation before going live. Running a full end-to-end test in the Fatoora Simulation Portal before production is strongly advised. Errors caught in simulation cost far less than those in live invoicing. Non-compliance is treated as a tax violation, with escalating penalties.

Tax Amnesty and Compliance Reviews:

ZATCA has taken a more aggressive stance on historical audits. Critically, the penalty-waiver initiative has been extended a further six months, effective 1 July 2026 and running until 31 December 2026, covering VAT, CIT, WHT, Excise, and RETT. This gives multinationals a window to proactively review Transfer Pricing documentation and VAT returns, correct exposures via voluntary disclosure, and settle liabilities penalty-free before an audit surfaces them.

GCC Updates

Oman

Voluntary Advance Tax Payments for MNEs

The Oman Tax Authority (OTA) has announced the go-live of Release 2 of the Fawtara platform on 28 June 2026, following the Peppol testbed going live on 25 June 2026. The release represents an important milestone in the Fawtara rollout and marks the start of service provider accreditation enabling OpenPeppol test result submission to OTA for review and allowing taxpayers to manage their service provider relationships within Fawtara.

Third-party providers must complete OpenPeppol and Oman Test Suite certification and obtain OTA approval before serving taxpayers. Built on the Peppol five-corner model, Fawtara routes structured invoices through accredited providers while reporting tax data to OTA in near real time. This positions Oman as the third GCC country to mandate e-invoicing, with Phase 1 obligations beginning August 2026 for the first cohort of large taxpayers.

Stricter VAT Audits & Direct Tax Focus

The OTA has intensified VAT audits, specifically focusing on input tax recovery documentation and the validity of zero-rated supplies. Businesses should ensure recovery claims are fully substantiated and zero-rating conditions clearly evidenced. Direct tax compliance remains under a microscope, with OTA demanding robust documentation for cross-border payments and intercompany services. Transfer Pricing support — proving arrangements meet the arm’s length standard is increasingly central to withstanding scrutiny.

Qatar

Adopting both the DMTT and the Income Inclusion Rule (IIR). Coverage extends to free zone entities, including the Qatar Financial Centre (QFC), and Qatari-headquartered MNEs must apply top-up tax to foreign low-taxed subsidiaries. A penalty regime applies, with transitional relief for fiscal years beginning before 31 December 2026.

Bahrain

Implemented a Domestic Minimum Top-up Tax (DMTT) under Decree-Law No. 11 of 2024. As a historically nil corporate-tax jurisdiction, it introduced the DMTT to retain primary taxing rights over top-up tax arising locally. Registration deadlines are already live, and the National Bureau for Revenue has issued scope, registration, and Transfer Pricing guidance.

Both Bahrain and Qatar have enacted the OECD’s 15% global minimum tax, effective 1 January 2025, applying to MNE groups with EUR 750 million+ consolidated revenue in at least two of the prior four fiscal years.

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