Worked positions · Ungated
Positions, not claims
Each of these is a real computation on a stated set of facts: the classification, the arithmetic, every citation to the article, and — where the answer turns on something the engine cannot know — an explicit refusal rather than a guess. Nothing is behind a form.
Intellectual Property
Commentary routinely says related-party R&D is excluded from the nexus fraction. It is not: R&D outsourced to any Person IN the State qualifies, related or not. Getting this backwards overstates the tax.
Digital Assets
The lot-matching convention that produces the SMALLEST gain carries the LARGEST tax bill. For a Qualifying Free Zone Person the holding period decides what can be Qualifying Income, so minimising the gain is the intuitive move and the wrong one.
Digital Assets
Nil basis on an airdrop is the aggressive position dressed as the cautious one. It recognises nothing today and costs MORE across two periods, because basis forgone now is gain recognised later — moved out of a year the AED 375,000 band would have absorbed it, into a year where the band is already spent.
And how the model is constrained
A position is only worth what the process behind it refuses to do. The advisory layer never produces a number: every figure in generated prose must trace to a verified engine result, or the memo is discarded. That gate runs on its own page, including the case it rejects and the gap it does not close.