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.

Arakan Forensic | UAE Tax Intelligence

A **Taxable Person** is the foundational legal subject of the UAE Corporate Tax regime. Under **Article 11**, this classification determines the scope of tax liability, mandating registration and compliance for both Resident and Non-Resident entities operating within the State.

The Resident vs. Non-Resident Binary

The 2026 audit framework categorizes Taxable Persons into two distinct pillars. Determining your pillar is the first step in forensic tax architecture:

Resident Persons

Includes any Juridical Person incorporated in the UAE (including Free Zones) or a foreign entity effectively managed and controlled here.

• Mainland LLCs & Joint Stock Companies.
• Free Zone Entities (FZEs) and Branch Offices.
• Natural Persons (Individuals) conducting business with turnover > AED 1M.

Non-Resident Persons

Foreign entities that derive UAE-sourced income but are not classified as Resident Persons.

• Entities with a Permanent Establishment (PE) in the UAE.
• Entities deriving state-sourced income (subject to Withholding Tax).
• Entities with a 'Nexus' in the State (Real Estate income).

The 'Natural Person' Threshold Warning

For individual entrepreneurs and freelancers, being a "Taxable Person" is contingent on revenue. If your gross turnover from business activities in the UAE exceeds **AED 1,000,000** within a calendar year, you are classified as a Taxable Person and must register with the FTA, regardless of whether you operate through a company or your personal name.

Exemptions and QFZP Nuance

While Free Zone companies are "Taxable Persons," those that qualify as **Qualifying Free Zone Persons (QFZP)** benefit from a 0% rate. However, being "Taxable" still requires them to file a Tax Return, maintain audited financials, and comply with all administrative mandates of the Decree-Law.

"In the 2026 enforcement era, the FTA presumes all juridical persons are Taxable Persons until proven exempt. Silence is not an exemption; it is a registration risk that carries an AED 10,000 penalty for late filing."
— Arakan Statutory Intelligence Brief

Related Statutory Concepts

Solution

Corporate Tax Strategy

Data Node

Sovereign Risk Matrix