**CIGA** (Core Income-Generating Activities) serves as the primary forensic anchor for Determining a **Qualifying Free Zone Person (QFZP)** status. In the 2026 enforcement era, CIGA is the difference between a 0% tax holiday and a standard 9% Corporate Tax liability.
Forensic Verification of CIGA
Under **Cabinet Decision No. 100**, CIGA must be physically performed within the specific Free Zone (or a Designated Zone for distribution) by the taxpayer or an adequate level of qualified employees. The FTA’s 2026 audit framework utilizes **Mass-Balance Principles** to verify these activities:
Technical Substance
Physical presence of assets (servers, machinery, labs) necessary for income generation.
Human Capital
Full-time employees (FTEs) commensurate with the complexity of the qualifying activity.
Expenditure
Operational expenditure (OPEX) incurred within the UAE, excluding non-UAE pass-throughs.
The modified Nexus Approach for IP
For entities claiming 0% on Intellectual Property (IP), CIGA is calculated using the **Nexus Ratio**. This requires tracking every dirham of R&D spend to ensure it was incurred locally. Arakan's Protocol automates this by linking the **Digital Pulse** of your engineering/creative teams directly to your tax ledger.
"CIGA is not a 'paper check'; it is an operational reality. If your income is generated by a server in Frankfurt or a designer in London, your UAE substance is technically compromised."
— Arakan Audit Briefing, Q1 2026