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 DSP a Qualifying Free Zone for 0% Corporate Tax?

Yes, Dubai Science Park 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 DSP?

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

DSP
Compliance Blueprint.

Forensic Node Active // Dubai

Statutory DNA Mapping // v1.0.26

The Sovereign Verdict

The Scientific Sovereign; High-Stakes R&D and IP Localization.

Strategic Overview

DSP is the UAE's premier hub for the life sciences. For 2026, the primary forensic challenge is the 'Modified Nexus Approach' (Action 5). For a pharma or biotech firm to claim 0% on royalties or patent income, they must prove the R&D wasn't just 'managed' here, but 'executed' here. This requires a granular link between laboratory bench-time, scientist payroll, and the resulting IP revenue.

I. Statutory Basis

As a Qualifying Free Zone Person, this jurisdiction requires strict adherence to Core Income-Generating Activities.Non-Designated Zone. QFZP status is strictly applied to 'Qualifying Intellectual Property' and specialized scientific research. Compliance centers on Article 18 and MD 229, requiring a clear audit trail of localized R&D expenditure.

Compliance Roadmap

01
R&D Statutory File: Implementing a project-based cost accounting system to track every dirham of localized research spend
02
Laboratory Asset Verification: Documenting the serial numbers and location of high-value lab equipment used in CIGA
03
Pharma Revenue Splitting: Forensically separating 'Trading/Distribution' (9%) from 'Patented Research' income (0%)

Audit Hotspots

Treating standard pharmaceutical distribution as 0% 'Qualifying' R&D income
Inadequate tracking of 'Contract Research' performed for foreign parent companies
Assuming laboratory 'Management' satisfies the physical 'Execution' requirement for IP Nexus

Sovereign Link Architecture

Jurisdictional Connectivity

Global Parent

15%

DSP

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 DSP.

Initiate Forensic Scan

Support

Expert Consultation

Discuss your DSP structure with our senior forensic partners.

Semantic Topic Cluster

Lexicon

QFZP Status

Lexicon

CIGA Audit

Briefing

2026 Readiness

Tool

License Checker