significantly influences the determination of the location of Multinational
Enterprises (“MNEs”). With the introduction of a Corporate Tax (“CT”) regime
starting 01 June 2023, MNEs will be substantially impacted.
of UAE CT
to the UAE CT, payment and compliances will be due if an entity is- Effectively
controlled or managed in the UAE / operated through a permanent establishment
in the UAE / earning UAE sourced income.
with related parties in the UAE will be regulated under the UAE Transfer
Pricing (“TP”) provisions.
and gain on sale of shares will be tax exempt.
Global minimum tax and UAE CT
global revenue exceeding EUR 750 million will be subject to 15% tax rate.
tax rate of less than 15% will be liable for a top up tax.
may adopt the Pillar 2 rules and specify a different tax rate.
Determination of PoEM, PE in the
UAE, and Nexus.
Litigation in the UAE due to
limited guidance and divergent views.
Potential double tax issues and
benefits under the tax treaties in country of residence and/or UAE.
Attribution of profits to the PE in
Additional compliance costs and
administrative burden for businesses.
Rigorous scrutiny by the competent
tax authority to mitigate tax evasion.
In depth analysis of the existing
or proposed business structures, transactions, arrangements and operations in the UAE to evaluate the UAE CT
Evaluating the risk of PE in the
UAE and identifying the impact of the potential PE on business.
Advising on business restructuring
to optimize the tax costs and in documentation to support the tax positions.
Assisting and advising on the tax