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 FFZ a Qualifying Free Zone for 0% Corporate Tax?

Yes, Fujairah Free Zone 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 FFZ?

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

FFZ
Compliance Blueprint.

Forensic Node Active // Fujairah

Statutory DNA Mapping // v1.0.26

The Sovereign Verdict

The Maritime Logistics Hub; Specialized in 'Outside-the-State' VAT Integrity.

Strategic Overview

Fujairah Free Zone is a critical logistics node adjacent to the Port of Fujairah. For 2026, the primary forensic challenge is 'Customs Data Synchronization.' As a Designated Zone, it is treated as 'Outside the UAE' for VAT on goods, but only if the goods do not enter the mainland. Any supply of goods to the mainland triggers a 9% tax event if the 5% de-minimis cap is exceeded. Logistics firms must provide 'Transaction-Level Traceability' to prove goods remained within the bonded area.

I. Statutory Basis

As a Qualifying Free Zone Person, this jurisdiction requires strict adherence to Core Income-Generating Activities.Statutory Designated Zone. Article 18 QFZP status centers on the 'Distribution' activity, requiring annual statutory audits and strict WPS alignment for the logistics labor force.

Compliance Roadmap

01
Daily Bill of Entry Audit: Automated matching of port-side customs documents to tax-basis revenue records
02
WPS Payroll Alignment: Linking localized staff presence to the 'Headquarter and Logistics' CIGA requirements
03
Service Ring-Fencing: Segregating 0% 'Port Services' from 9% 'Mainland Consultancy' or administrative revenue

Audit Hotspots

Mixing Port-side qualifying logistics with non-qualifying Mainland-sourced consulting income
Inadequate documentation for 'High-Seas' trading where the bill of lading is the only proof of substance
Failure to reconcile VAT-suspended imports with the final tax-return turnover

Sovereign Link Architecture

Jurisdictional Connectivity

Global Parent

15%

FFZ

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 FFZ.

Initiate Forensic Scan

Support

Expert Consultation

Discuss your FFZ structure with our senior forensic partners.

Semantic Topic Cluster

Lexicon

QFZP Status

Lexicon

CIGA Audit

Briefing

2026 Readiness

Tool

License Checker