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 DMC a Qualifying Free Zone for 0% Corporate Tax?

Yes, Dubai Maritime City 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 DMC?

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

DMC
Compliance Blueprint.

Forensic Node Active // Dubai

Statutory DNA Mapping // v1.0.26

The Sovereign Verdict

The Sovereign Maritime Node; Specialized in Heavy Asset CIGA.

Strategic Overview

Dubai Maritime City is a unique industrial hub. For 2026, the primary forensic hurdle is 'Operational Ring-Fencing.' While 'Ship Repair' and 'Yacht Manufacturing' are Qualifying Activities, the administrative 'Management' of ships often falls into a different tax bucket. Entities must prove that their dry-dock CIGA (Core Income-Generating Activities) occurs physically within the DMC precinct to justify the 0% rate and avoid the 9% mainland service trap.

I. Statutory Basis

As a Qualifying Free Zone Person, this jurisdiction requires strict adherence to Core Income-Generating Activities.Designated Zone status for VAT. Corporate Tax compliance is governed by Article 18, with a specific focus on manufacturing and processing within the maritime sector as defined under Cabinet Decision No. 100.

Compliance Roadmap

01
Dry-Dock CIGA Verification: Maintaining a daily technical log of repair and manufacturing activities performed on-site
02
Technical Labor Audit: Utilizing WPS (Wages Protection System) data to prove that engineers and shipwrights are localized to the DMC unit
03
Asset-Based Substantiation: Documenting high-value machinery and Capex investment to support the 'High Substance' rating

Audit Hotspots

Mixing offshore 'Ship Management' services (taxable) with on-site 'Manufacturing' (qualifying)
Inadequate documentation for 'Spare Parts' inventory moving from the Designated Zone to mainland vessels
Failing to separate technical repair fees from taxable 'Consulting' income

Sovereign Link Architecture

Jurisdictional Connectivity

Global Parent

15%

DMC

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 DMC.

Initiate Forensic Scan

Support

Expert Consultation

Discuss your DMC structure with our senior forensic partners.

Semantic Topic Cluster

Lexicon

QFZP Status

Lexicon

CIGA Audit

Briefing

2026 Readiness

Tool

License Checker