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 RAKEZ a Qualifying Free Zone for 0% Corporate Tax?

Yes, Ras Al Khaimah Economic 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 RAKEZ?

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

RAKEZ
Compliance Blueprint.

Forensic Node Active // RAK

Statutory DNA Mapping // v1.0.26

The Sovereign Verdict

Consolidated Industrial Node; Legacy License Migration Risk.

Strategic Overview

RAKEZ is the result of the consolidation of RAKIA and RAKFTZ. For 2026, the primary forensic challenge is 'Statutory Legacy Management.' Many entities still operating under older RAKIA frameworks may find their 'Qualifying Activity' status challenged if their license terms haven't been meticulously mapped to the newest Decree-Law 47 standards. For industrial manufacturing, the focus remains on local physical CIGA and asset-backed substance.

I. Statutory Basis

As a Qualifying Free Zone Person, this jurisdiction requires strict adherence to Core Income-Generating Activities.Centralized RAK jurisdiction. Article 18 compliance centers on local physical CIGA. Legacy licenses must be audited to ensure 'Qualifying Free Zone Person' status is not disqualified due to outdated activity descriptions.

Compliance Roadmap

01
Legacy Audit: Comprehensive review of RAKIA/RAKFTZ legacy terms against 2026 statutory definitions
02
Annual Financial Audit: Mandatory filing of audited accounts to substantiate QFZP 0% claims
03
Physical Lease Verification: Documenting that industrial 'Core Income-Generating Activities' are performed within the RAK perimeter

Audit Hotspots

Failing to update legacy license terms to 2026 standards, leading to 'Excluded Activity' reclassification
Missing the mandatory 9-month registration window for older RAKIA entities
Assuming 'Virtual' presence satisfies the Article 18 physical asset requirement for industrial firms

Sovereign Link Architecture

Jurisdictional Connectivity

Global Parent

15%

RAKEZ

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 RAKEZ.

Initiate Forensic Scan

Support

Expert Consultation

Discuss your RAKEZ structure with our senior forensic partners.

Semantic Topic Cluster

Lexicon

QFZP Status

Lexicon

CIGA Audit

Briefing

2026 Readiness

Tool

License Checker