Scout / Business Plan Review
A plan can be internally inconsistent without anyone noticing until the licensing or bank-account stage — claiming a 0% tax structure while planning mainland revenue, or assuming a virtual office works in a jurisdiction that requires a physical one. Scout's paradox engine checks a business plan against a deterministic rule set covering tax structure, ownership, substance, and office type before you commit to a jurisdiction. Below are real categories of contradiction it catches.
Tax structure
QFZP exemption invalidated by mainland trading
A Qualifying Free Zone Person cannot conduct direct B2C retail or distribution on the UAE mainland without losing the 0% corporate tax rate — mainland-facing revenue falls under the standard 9% rate. This is one of the most common contradictions in plans that assume 'free zone' means 'tax-free everywhere.'
UAE Corporate Tax Law (Federal Decree-Law No. 47 of 2022) — QFZP qualifying income rules; MoF Ministerial Decision No. 265 of 2023
Substance
Economic substance risk with a virtual office
A high-profit free zone entity claiming corporate tax exemption must demonstrate genuine economic substance — adequate employees, expenditure, and physical presence. A virtual office alone may not satisfy this, undermining the exemption the plan is built around.
UAE Economic Substance Regulations (Cabinet Resolution No. 57 of 2020)
Tax structure
Place of Effective Management risk from non-UAE-resident directors
If key management decisions are made by non-UAE-resident directors, the parent jurisdiction's tax authority can argue the company is effectively managed — and therefore taxable — outside the UAE, regardless of where it's incorporated.
OECD Model Tax Convention, Place of Effective Management principle; bilateral DTAA provisions
Ownership
Individual ownership plus high repatriation intent creates transfer pricing exposure
High-value related-party transactions between an individually-owned UAE entity and overseas accounts often lack the corporate holding structure needed to defend transfer pricing under arm's-length principles — a gap examiners look for specifically.
UAE CT Law transfer pricing provisions (related-party transactions above AED 3M)
Office type
Virtual office incompatible with the chosen jurisdiction
Some jurisdictions (ADGM and DIFC among them) mandate a physical registered office address as a condition of registration — a virtual-office plan for these zones is a hard block, not a soft preference.
ADGM/DIFC Registration Authority Rules — physical address requirement
Office type
Headcount plan exceeds what the office type can support
Visa-to-desk ratios are enforced by immigration authorities, not just free zone policy. A hiring plan built before the office type is confirmed frequently exceeds what a virtual or flexi-desk arrangement can actually sponsor.
MoHRE visa-to-desk quota rules; zone-specific office tier policies
These contradictions are cheap to fix on paper and expensive to fix after a licence is issued. A structure built on a plan that trips one of these rules typically surfaces the problem at the bank account stage, the audit stage, or — worst case — a tax authority review years later. The categories above (tax structure, substance, ownership, office type) are checked deterministically against your specific profile, not estimated from a generic template.