**Connected Persons** refers to individuals who possess a position of influence over a Taxable Person, specifically targeting owners, directors, and their fourth-degree relatives. Under the 2026 statutory framework, payments to these individuals are the most heavily audited expense category in the UAE.
The Market Value Test (Article 35)
The primary purpose of **Article 35** is to prevent profit stripping. An expense incurred for a payment to a Connected Person is deductible only to the extent that it represents the **Market Value** of the service provided. The FTA defines "Connected Persons" as:
Owners & Partners
Any individual who directly or indirectly owns or controls the Taxable Person.
Officers & Directors
Managers, board members, or anyone with functional executive control.
Kinship (4th Degree)
Relatives of the above, up to the fourth degree (cousins, great-aunts/uncles).
Remuneration Forensics
In 2026, the FTA no longer accepts "Owner Salary" as a blanket deduction. If a Managing Director of a small Free Zone entity is paid AED 200,000 per month while the market average is AED 50,000, the AED 150,000 variance is **Non-Deductible**. This amount is added back to the taxable profit, effectively taxing the owner's "excessive" salary at 9%.
Forensic Documentation with Arakan
Arakan's Protocol flags payments to **Ultimate Beneficial Owners (UBOs)** and compares them against our **Sovereign Salary Index**. Our system requires a "Functional Role Description" to be cryptographically linked to each salary payment, providing the forensic proof needed to justify deductibility during a Tax Audit.
"The FTA views Connected Person payments as a 'De Facto Dividend.' If you cannot prove that you would pay a third-party stranger the same amount for the same work, the deduction will be disallowed."
— Arakan Statutory Intelligence Brief