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 FOIZ a Qualifying Free Zone for 0% Corporate Tax?

Yes, Fujairah Oil Industry 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 FOIZ?

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

FOIZ
Compliance Blueprint.

Forensic Node Active // Fujairah

Statutory DNA Mapping // v1.0.26

The Sovereign Verdict

The Energy Giant; Specialized in Extractive vs. Non-Extractive Forensic Splits.

Strategic Overview

FOIZ is one of the world's largest bunkering hubs. For 2026, the forensic challenge is the 'Article 2 Split.' Income from 'Extractive' activities (drilling, production) is typically exempt from Federal Corporate Tax as it is taxed at the Emirate level. However, 'Non-Extractive' activities (trading, storage, bunkering) are subject to Decree-Law 47. Entities must perform a forensic audit of their revenue streams to ensure they are not paying Federal tax on exempt Emirate-taxed income, or vice versa.

I. Statutory Basis

As a Qualifying Free Zone Person, this jurisdiction requires strict adherence to Core Income-Generating Activities.Specific Oil Law overrides apply. Statutory nexus is defined by the intersection of Federal Decree-Law 47 (Article 2) and local Fujairah energy decrees. Requires specialized bunkering-bill audits.

Compliance Roadmap

01
Specialized Extractive Audit: Segmenting upstream 'Extractive' income (Exempt) from midstream 'Bunkering/Trading' income (Taxable/QFZP)
02
Bunkering Bill Forensic Trail: Reconciling ship-to-ship transfer logs with customs-bonded storage data to justify 0% QFZP status on trading
03
Article 34 Transfer Pricing: Establishing arm's-length benchmarks for inter-company fuel storage and throughput agreements

Audit Hotspots

Incorrectly applying Federal CT to 'Extractive' income that is already taxed at the Emirate level (Overpayment)
Failing to document CIGA for 'High-Seas' bunkering trades conducted from FOIZ offices
Inadequate ring-fencing of 'Storage Fees' which may be treated as non-qualifying income if not properly structured

Sovereign Link Architecture

Jurisdictional Connectivity

Global Parent

15%

FOIZ

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 FOIZ.

Initiate Forensic Scan

Support

Expert Consultation

Discuss your FOIZ structure with our senior forensic partners.

Semantic Topic Cluster

Lexicon

QFZP Status

Lexicon

CIGA Audit

Briefing

2026 Readiness

Tool

License Checker