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 DPC a Qualifying Free Zone for 0% Corporate Tax?

Yes, Dubai Production 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 DPC?

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

DPC
Compliance Blueprint.

Forensic Node Active // Dubai

Statutory DNA Mapping // v1.0.26

The Sovereign Verdict

Industrial Design District; High-Substance Manufacturing Hub.

Strategic Overview

DPC functions as a high-substance Designated Zone (DZ) for VAT purposes, which translates to a rigorous Corporate Tax audit profile. For 2026, the forensic hurdle is 'Activity Characterization.' While 'Manufacturing and Processing' is a primary Qualifying Activity, administrative fees or purely 'Trading' income (if the goods do not physically move through the DZ) may be excluded. Industrial units must perform a 'Utility-to-Output' reconciliation to prove that 0% tax is only claimed on genuine manufacturing value-add produced within the zone.

I. Statutory Basis

As a Qualifying Free Zone Person, this jurisdiction requires strict adherence to Core Income-Generating Activities.Qualifying Income is derived from 'Manufacturing and Processing' under Cabinet Decision No. 100 of 2023. As a Designated Zone, it allows for VAT-suspended goods movement, provided the forensic trail for export is maintained via Bill of Entry (BoE) documentation.

Compliance Roadmap

01
Utility-to-CIGA Mapping: Correlating DEWA consumption with production output to provide forensic proof of physical substance
02
Inventory-to-Sales Reconciliation: Maintaining a 'Zero-Discrepancy' log between raw material imports and finished product sales
03
Manufacturing-only 0% Claim: Rigorously segregating 0% manufacturing revenue from 9% administrative or consulting fees

Audit Hotspots

Applying the 0% rate to non-manufacturing administrative fees or auxiliary consulting income
Stock discrepancies identified during physical FTA site audits of industrial warehouses
Co-mingling mainland retail distribution profit with global wholesale export ledgers

Sovereign Link Architecture

Jurisdictional Connectivity

Global Parent

15%

DPC

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 DPC.

Initiate Forensic Scan

Support

Expert Consultation

Discuss your DPC structure with our senior forensic partners.

Semantic Topic Cluster

Lexicon

QFZP Status

Lexicon

CIGA Audit

Briefing

2026 Readiness

Tool

License Checker