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Lexicon
Lexicon

Understanding CIGA (Core Income Generating Activities)

Lexicon Entry: The Substance Requirement Standard for 2026

**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
[Image showing the relationship between Core Income Generating Activities (CIGA), Economic Substance, and the 0% Tax Threshold in the UAE]

Related Concepts

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Corporate Tax Strategy

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Free zone risk matrix

Disclaimer: This lexicon entry is for informational purposes only and does not constitute legal or tax advice. Arakan recommends a formal nexus assessment for all entities under Decree-Law 47.

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