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 SPC a Qualifying Free Zone for 0% Corporate Tax?

Yes, Sharjah Publishing 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 SPC?

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

SPC
Compliance Blueprint.

Forensic Node Active // Sharjah

Statutory DNA Mapping // v1.0.26

The Sovereign Verdict

High-Efficiency Trading Node; The Dual-License Ring-Fencing Specialist.

Strategic Overview

SPC is the world's first dedicated publishing hub, but in 2026, it has evolved into a powerhouse for general trading and e-commerce. The unique 'Dual-License' feature allows entities to trade with the mainland instantly, but this creates a massive forensic burden. Without rigid P&L segregation, mainland revenue can 'taint' the 0% Free Zone pool, leading to a full 9% reassessment by the Federal Tax Authority.

I. Statutory Basis

As a Qualifying Free Zone Person, this jurisdiction requires strict adherence to Core Income-Generating Activities.Statutory eligibility for 0% Corporate Tax hinges on Article 18 QFZP status. For SPC entities, the focus is on the 'Distribution' of goods and 'Printing' activities, which must be clearly mapped against Core Income-Generating Activities (CIGA) performed within the zone.

Compliance Roadmap

01
Rigid P&L Segregation: Implementing separate ledgers for 'Free Zone to Global' vs 'Dual-License Mainland' activities
02
Substance Anchor: Maintaining a physical office footprint in Sharjah to satisfy the Article 18 'Main Management' test
03
Statutory Registration: Ensuring Corporate Tax registration is completed regardless of 'Zero-Visa' or 'Virtual Office' status

Audit Hotspots

Failing to register for Corporate Tax due to the misconception that 'Zero-Visa' licenses are exempt
Co-mingling mainland retail revenue with global export profit pools
Inadequate documentation of the 'Place of Effective Management' (POEM) for remote-operated trading firms

Sovereign Link Architecture

Jurisdictional Connectivity

Global Parent

15%

SPC

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 SPC.

Initiate Forensic Scan

Support

Expert Consultation

Discuss your SPC structure with our senior forensic partners.

Semantic Topic Cluster

Lexicon

QFZP Status

Lexicon

CIGA Audit

Briefing

2026 Readiness

Tool

License Checker