What are the UAE Corporate Tax record-keeping requirements for 2026?

Under Federal Decree-Law No. 47 and Article 52 of the Tax Procedures Law, taxable persons must maintain records for 7 years. Arakan Protocol ensures these records remain in-situ within the UAE digital perimeter to satisfy data residency mandates.

How does Pillar Two affect multinational groups in the UAE?

Pillar Two introduces a 15% global minimum tax for MNE groups with revenues exceeding EUR 750 million. Arakan provides automated GloBE substantiation and jurisdictional nexus mapping to manage top-up tax liabilities.

What is the 0% Qualifying Free Zone Person (QFZP) status?

A QFZP is a Free Zone entity that maintains adequate substance in the UAE and derives Qualifying Income. Failure to demonstrate Core Income Generating Activities (CIGA) can result in a retroactive 9% tax liability.

Syncing_Statutory_View...

System DNA Synchronized

Initializing Ledger...

ID: 00000000 // Vault Protocol

Compliance

0% Readiness

Exposure Detected

Jurisdiction

Mainland

Standard Regime

Article 18 Status

NON-QUALIFYING

Real-time Assessment

Index

Verify Competency

Node 1 Node 2

Part I

Registry Key: TP-NEXUS

The Arm's Length Principle

Advanced

Statutory

Establishing Your ALP Foundation

Identify All 'Connected Persons'

Map your ownership structure to find all relatives, partners, and affiliates that fall under the 50%+ control rule.

Draft Inter-Company Agreements

Formalize all internal services and loans with written contracts that specify market-based interest rates and service fees.

Shield Verified: TP-NEXUS

1.1 The Article 34 Framework

All Related Party transactions must satisfy the Arm's Length Standard, ensuring pricing mirrors open market conditions.

▶Pricing must reflect unrelated party agreements.
▶Applies to domestic and international nexus.
▶Forensic documentation prevents artificial profit shifting.

1.2 FAR Analysis

The FAR Analysis (Functions, Assets, Risks) is the mandatory forensic tool used to justify inter-company margins.

▶Identify core profit-generating work.
▶Verify IP and asset ownership.
▶Map financial risk allocation across the group.

Statutory Reference

Demonstrate Proficiency

Validate your knowledge of this node to mint your verifiable forensic credential.

Begin Assessment Protocol

Statutory Clarifications (FAQ)

Q: Does Transfer Pricing apply to domestic transactions within the UAE?

A: Yes. Article 34 applies to both domestic and international transactions between Related Parties, including transactions between a Mainland entity and its Free Zone branch.

Current Focus

The Arm's Length Principle

Pass Quiz

Next Chapter

The Three-Tier Documentation Standard