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.

Who is considered an Ultimate Beneficial Owner (UBO)?

A UBO is any natural person (human) who ultimately owns or controls 25% or more of a company's shares or voting rights. If no such person exists, the UBO is the person who holds the position of 'Senior Managing Official'.

What is the 'goAML' portal used for?

The goAML portal is a unified digital platform used by the UAE Financial Intelligence Unit. Designated businesses (DNFBPs) must use it to report suspicious transactions (STR) or activity (SAR) that may be linked to money laundering.

How quickly must I update the UBO register after a change?

Under Cabinet Decision No. 109, any change to the Beneficial Owner information must be updated in the company's internal register and submitted to the licensing authority within 15 days of the change.

Section I

Governance (AML & UBO)

Expert Level

How to Comply with the UAE UBO Mandate

Identify the Natural Persons

Apply the 'Look-Through' principle to trace ownership through any parent companies or holding structures until you identify the specific individuals holding 25% or more control.

Maintain an Internal UBO Register

Create a formal document containing the names, nationalities, and passport details of all identified UBOs, ensuring it is kept at the company's registered office.

Submit Data to the Licensing Authority

Log into your relevant authority portal (e.g., DED or Free Zone) and upload the UBO declaration to link the human controllers to the trade license.

Official References

8.1 goAML Registration & Suspicious Activity Reporting (SAR)

Under the UAE’s intensified AML/CFT framework, Designated Non-Financial Businesses and Professions (DNFBPs)—including real estate agents, gold dealers, auditors, and corporate service providers—must be registered on the goAML portal. In 2026, compliance involves more than just registration; entities must actively file Suspicious Activity Reports (SAR) or Suspicious Transaction Reports (STR) whenever a transaction lacks a clear economic purpose or involves high-risk jurisdictions. Failure to maintain an active goAML profile or neglecting to appoint a dedicated Compliance Officer can lead to license suspension and heavy federal fines.

8.2 The Ultimate Beneficial Owner (UBO) Mandate

Cabinet Decision No. 109 mandates that all legal entities registered in the UAE (Mainland and Free Zone) maintain a Real-Time UBO Register. A UBO is defined as any natural person who ultimately owns or controls 25% or more of the company's shares or voting rights. In 2026, this register must be submitted to the relevant licensing authority (e.g., DED or Free Zone Authority) and updated within 15 days of any change. The 'Look-Through' principle is strictly applied, meaning companies cannot hide behind complex holding structures or nomadic corporate shells to obscure the true human controller.

8.3 Economic Substance Regulations (ESR) & Reporting

Complementing AML efforts, Economic Substance Regulations (ESR) require companies performing 'Relevant Activities' (such as Banking, Insurance, or Headquarters Business) to prove they earn 'core income' within the UAE. In 2026, the ESR notification and annual report are critical data points that the FTA uses to validate Corporate Tax 'Substance' claims. Misalignment between your ESR filings and your Tax returns is a high-priority trigger for a joint regulatory investigation, as it suggests the entity may be a 'shell' used for base erosion.