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.

Is ADGM a Qualifying Free Zone for 0% Corporate Tax?

Yes, Abu Dhabi Global Market is a jurisdiction where entities can qualify for a 0% rate under Decree-Law 47, provided they maintain adequate substance and meet CIGA requirements. Arakan AI automates this forensic audit.

What are the CIGA requirements for ADGM?

Core Income-Generating Activities in ADGM must be performed within the zone, involving adequate assets and qualified employees. Arakan Forensic maps these statutory requirements against your actual operations.

ADGM
Compliance Blueprint.

Forensic Node Active // Abu Dhabi

Statutory DNA Mapping // v1.0.26

The Sovereign Verdict

The Sovereign Financial Node; English Common Law Jurisdiction.

Strategic Overview

ADGM is a premier international financial centre (IFC) that directly applies English Common Law, providing a level of legal certainty unique within the region. For 2026, the primary forensic challenge is the 'Dual-License' bridge—where entities operate simultaneously in the Free Zone and Mainland. This requires rigid ring-fencing of accounts to prevent the 9% mainland tax from 'infecting' the 0% qualifying free zone income.

I. Statutory Basis

As a Qualifying Free Zone Person, this jurisdiction requires strict adherence to Core Income-Generating Activities.Operates as an independent jurisdiction fully integrated with the UAE Federal Tax framework. Compliance is governed by the ADGM Registration Authority and the FSRA, requiring annual IFRS-compliant audits by ADGM-registered auditors.

Compliance Roadmap

01
Mandatory annual statutory audit by an ADGM-registered auditor (IFRS Standards)
02
Pillar Two (Global Minimum Tax) assessment for MNEs exceeding the €750M revenue threshold
03
Strict 'Dual-License' accounting separation between ADGM and Abu Dhabi DED activities

Audit Hotspots

Inadequate board minutes failing to prove the 'Place of Effective Management'
Non-financial holding companies skipping mandatory Economic Substance (ESR) filings
Late Corporate Tax registration (Penalty: AED 10,000)

Sovereign Link Architecture

Jurisdictional Connectivity

Global Parent

15%

ADGM

Live Node

Dubai Mainland

Forensic Brief

Qualifying Income requires physical CIGA within the zone boundaries. Article 18 mapping is mandatory to maintain 0% status.

Statutory Audit

Full forensic substantiation for ADGM.

Initiate Forensic Scan

Support

Expert Consultation

Discuss your ADGM structure with our senior forensic partners.

Semantic Topic Cluster

Lexicon

QFZP Status

Lexicon

CIGA Audit

Briefing

2026 Readiness

Tool

License Checker