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.

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Risk

Feb 17, 2026

10 min read

Transfer Pricing: The Nexus Trap

Related Party Compliance and Arm's Length Principle Enforcement in 2025/26

Arakan Statutory TeamStatutory Intelligence Lead

The Audit Focus

The FTA has signaled that Transfer Pricing (TP) will be the primary lever for revenue protection in the upcoming audit cycles. Any transaction between 'Connected Persons' must adhere to the Arm's Length Principle.

Primary Penalty

AED 50,000

Per instance of missing Master File documentation.

Forensic Nexus Mapping

Most conglomerates fail because their ERP systems lack the 'Nexus Layer' required to tag related-party transfers automatically. Arakan solves this by building a secondary forensic ledger in volatile memory.

Institutional Resource Available

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Technical Blueprint.

Move beyond the briefing. Access the full 2026 Forensic Framework for Transfer Pricing: The Nexus Trap, including statutory citations and audit-defense matrices.

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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

The Audit Focus

Primary Penalty

Forensic Nexus Mapping

Download the Technical Blueprint.

The Audit Focus

Primary Penalty

Forensic Nexus Mapping

Download the Technical Blueprint.

Download the
Technical Blueprint.

Download the
Technical Blueprint.