Insights & Perspectives

How Should UAE-Headquartered Groups Structure Holdings, IP and Financing Under Pillar Two?

Pillar Two changes the objective from finding the lowest rate to building a commercially sound structure that remains efficient after jurisdictional blending and a 15% floor.

Why Does 9% UAE Corporate Tax Not Simply Mean a 6% Pillar Two Top-up?

The UAE's 9% Corporate Tax rate is not automatically topped up by 6%. Pillar Two uses a different income base, tax numerator and jurisdictional calculation.

How Does Transfer Pricing Change a UAE Pillar Two and DMTT Result?

Transfer pricing determines where group profit is recorded; Pillar Two tests the tax on that profit. See how UAE policies, true-ups and disputes affect DMTT.

Is Your UAE Pillar Two Data Ready? GloBE Calculation and GIR Checklist

Pillar Two is a cross-functional data programme. Use this UAE-focused checklist to prepare entity, accounting, tax, deferred-tax, substance and GIR data before filing.

Does the UAE Free Zone 0% Corporate Tax Rate Trigger Pillar Two Top-up Tax?

The 0% UAE free-zone rate remains available, but large multinational groups may face UAE DMTT. See who is affected, how blending and SBIE work, and what to model.

Can Your Group Avoid a Full GloBE Calculation? UAE Pillar Two Safe Harbours Explained

A practical UAE guide to the Pillar Two safe harbours, the three Transitional CbCR tests, the QDMTT Safe Harbour and the evidence multinational groups should prepare.

UAE Pillar Two ETR Calculation: A Worked DMTT Example

This worked example calculates a 6.84% UAE GloBE ETR, the 2025 substance-based exclusion and an indicative AED 28.59 million DMTT liability.

Best Transfer Pricing Firms in the UAE: What Should You Actually Look For?

Looking for the best transfer pricing firm in the UAE? Compare adviser types, understand UAE TP requirements, and see what separates a strong transfer pricing practice from a generic tax provider.

Transfer Pricing Services in Dubai, UAE: 2026 Guide to Corporate Tax, Related Parties and FTA Compliance

UAE transfer pricing guide covering Related Parties, Connected Persons, Local File, Master File, benchmarking, Free Zones, loans and FTA compliance.

UAE Pillar Two Information Return: Who Must File, What to Report and When

Ministerial Decision No. 133 of 2026 identifies the UAE entities that must file the Pillar Two Information Return and when a filing by the UPE or designated filing entity can discharge local filing.

UAE Pillar Two DMTT Guide 2026: Scope, 15% ETR and Filing Deadlines

The UAE’s Domestic Minimum Top-up Tax is now a live compliance regime, not a future policy proposal. Here is what an in-scope multinational group needs to know and do.

Pillar Two Updates June 2026: Global Minimum Tax Roundup

June 2026 brought a wave of Pillar Two developments — the OECD's GIR XML filing guidance, Side-by-Side adoption across four jurisdictions, and filing extensions in Portugal, Belgium and Turkey.

Achieving DMTT Readiness in Dubai: A Practical Guide for MNEs

Ministerial Decision No. 96 of 2026: UAE Pillar Two Guidance

Ministerial Decision No. 96 of 2026 adopts the latest OECD GloBE commentary and guidance for the UAE Top-Up Tax, replacing Ministerial Decision No. 88 of 2025 from 22 June 2026.

Saudi Transfer Pricing: What General Documentation Requires

General Documentation is Saudi Arabia's catch-all transfer pricing record for taxpayers exempt from the Local and Master File. It has no set format but must still prove related-party pricing is at arm's length.

UAE Corporate Tax: AED 10,000 Late Registration Penalty Waiver

The UAE Ministry of Finance and FTA will waive the AED 10,000 late corporate tax registration penalty if a business files its first tax return or annual declaration within seven months of its first tax period.

OECD Transfer Pricing Country Profiles Now Cover 83 Jurisdictions

The OECD has expanded its Transfer Pricing Country Profiles to 83 jurisdictions, adding 8 countries and giving multinationals a comparative map of how each applies the arm's length principle.

KSA Transfer Pricing: Local File and Master File Thresholds

In Saudi Arabia a Local File and Master File become mandatory once related-party transactions exceed SAR 6 million for taxpayers, or SAR 100 million for zakat payers during the 2024 to 2026 phase-in.

Bahrain's First Transfer Pricing Guide Under the DMTT

Bahrain's first transfer pricing guide (June 2026) requires in-scope multinational groups to price cross-border related-party dealings at arm's length under the DMTT, using five methods and two documentation tiers.

Business Restructuring in Saudi Arabia: SEZ and RHQ Routes

Saudi Arabia offers two government-backed restructuring routes — Special Economic Zones and the RHQ programme — and, with no domestic Pillar Two top-up tax yet in force, a window to realign operating models.

UAE Pillar Two Top-Up Tax Registration on EmaraTax: A Guide

The FTA has added a dedicated Pillar Two Top-Up Tax Registration service on EmaraTax, letting in-scope MNE groups register under the UAE's DMTT regime as an individual entity or a designated filing entity.

UAE Family Foundations Guide 2026: What the CTGFF1 Update Changes

The FTA's June 2026 Family Foundations Corporate Tax Guide keeps the Article 17 fiscal-transparency conditions but clarifies that LLCs are not similar entities and adds asset-transfer and family-office rules.

KSA Transfer Pricing Penalties for Non-Compliance

Missing Saudi Arabia's transfer pricing disclosure deadline triggers a penalty of at least 1% of revenue, while misrepresentation can cost 25% of the tax difference and late payment adds 1% every 30 days.

Zakat vs Corporate Income Tax in Saudi Arabia Explained

In Saudi Arabia, zakat applies to Saudi and GCC ownership at 2.5%, while corporate income tax applies to non-GCC ownership at 20%. A mixed-ownership company pays both, on separately computed bases.

Revised UAE Federal Tax Authority Service Fees Effective from 1 January 2026

The UAE Cabinet has introduced revised Federal Tax Authority (FTA) service fees effective from 1 January 2026. Explore updated charges for TRC services, tax agent registration, designated zones, clarification requests, and advance pricing agreements.

UAE Family Foundations and Corporate Tax: Complete Guide for Wealth Preservation in 2025

Discover how UAE Family Foundations are taxed under the latest Corporate Tax regulations. Learn about eligibility conditions, tax transparency, compliance requirements, multi-tier structures, and strategic wealth preservation benefits for families and investors in the UAE.

Cabinet Decision No. 17 of 2026: UAE Tax Procedures Update

Cabinet Decision No. 17 of 2026 amends the UAE Tax Procedures Executive Regulations from 1 April 2026, easing voluntary disclosures while setting a hard five-year refund deadline.

Cabinet Decision No. 129 of 2025: UAE Tax Penalty Changes

Cabinet Decision No. 129 of 2025 resets the UAE's administrative tax penalties from 14 April 2026, introducing a 14% annual late-payment charge and cutting several fixed penalties.

GCC Tax Compliance Calendar: May 2026 Deadlines

The key GCC tax deadlines for May 2026: the UAE corporate tax return with the TP Disclosure Form is due 31 May for year-ends of 31 August 2025, alongside VAT, excise and withholding tax filings across the region.

Qatar Extends the 2025 Tax Return Deadline to June 2026

Qatar's General Tax Authority has extended the deadline for filing 2025 tax year returns on the Dhareeba portal from 30 April to 30 June 2026 — for all taxpayers except the petroleum and petrochemical sectors.

Qatar's Capital Gains Tax Exemption for Group Restructuring

Qatar's Decision No. 3 of 2026, effective 2 March 2026, disregards capital gains on qualifying intra-group restructurings for income tax — subject to prior GTA approval and a clawback if conditions are later breached.

How UAE Corporate Tax Defines a Director and Officer (CTP010)

An FTA public clarification, CTP010, defines who is a Director or Officer under UAE Corporate Tax: natural persons with genuine decision-making authority, not job titles, making them Connected Persons.

Saudi Transfer Pricing Compliance and the 30 April Disclosure Form

In Saudi Arabia, any taxpayer with related-party transactions must file a Controlled Transaction Disclosure Form (CTDF) and auditor affidavit with the tax return within 120 days of the year-end.

Tariffs and Transfer Pricing: Managing the Twin Enforcement Trap

Customs wants intercompany values high to collect more duty; transfer pricing wants them low to raise taxable profit. This twin enforcement trap can leave UAE importers double taxed unless both positions align.

EmaraTax APA Programme Is Live: How to Apply in the UAE

The UAE's Advance Pricing Agreement programme is now live on the EmaraTax portal. Businesses can file APA pre-filing requests online for domestic transactions, following the FTA's 31 December 2025 guidance.

GCC Tax Compliance Calendar: April 2026 Deadlines

The key GCC tax deadlines for April 2026: the UAE corporate tax return with the TP Disclosure Form is due 30 April for year-ends of 31 July 2025, alongside VAT, excise, WHT and Zakat filings across the region.

Global Transfer Pricing Updates 2026: Five Jurisdictions to Watch

March 2026 brought new transfer pricing obligations across five jurisdictions, from Colombia's return adjustments and Georgia's GEL 500,000 reporting threshold to Latvia's overhauled framework.

Pillar Two Global Updates 2026: Country Implementation Roundup

Across Sweden, the Netherlands, Japan, Greece, Ireland, Austria and Belgium, jurisdictions are refining their Pillar Two rules in 2026 — adopting the OECD Side-by-Side package and setting GloBE filing mechanics.

Economic Substance and Transfer Pricing Risk in Offshore Structures

Offshore entities that exist only on paper, with no people, functions or genuine decisions, risk having profits reallocated to where value is actually created under BEPS and UAE anti-avoidance rules.

Intragroup Services Transfer Pricing: The Benefit Test Explained

An intragroup service charge is arm's length only if it passes the benefit test: proof the activity gave the recipient economic value that an independent party would have paid for.

Qatar Introduces Pillar Two and a Domestic Minimum Top-Up Tax

Qatar has implemented OECD Pillar Two through Council of Ministers Resolution No. 2 of 2026, adding a Domestic Minimum Top-Up Tax that ensures a 15% effective rate for large multinational groups from FY2025.

UAE Advance Corporate Tax Payments: How the EmaraTax Option Works

From Financial Year 2026 the UAE FTA lets businesses make voluntary advance corporate tax payments through EmaraTax, credited to their account and offset against a future liability rather than a final tax.

Cabinet Decision No. 209 of 2025: UAE Tax Information Exchange

Cabinet Decision No. 209 of 2025 upgrades the legal framework the UAE uses to share tax information with foreign authorities on request, covering ownership, banking, entity and accounting records.

Bahrain DMTT: The 15% Domestic Minimum Top-Up Tax Explained

Bahrain's Domestic Minimum Top-Up Tax (DMTT), under Decree-Law No. 11 of 2024, imposes a 15% minimum effective tax rate on the Bahrain profits of large multinational groups from 1 January 2025.

Saudi Arabia's SEZ Bylaws 2026: CIT, Zakat, TP and WHT

Saudi Arabia's SEZ Regulatory Bylaws, issued under Cabinet Resolution No. 233, keep zone companies in corporate income tax but remove them from Zakat, while transfer pricing rules continue to apply in full.

ZATCA Extends Its Fines Cancellation Initiative to June 2026

ZATCA's initiative to cancel fines and exempt tax penalties now runs from 1 January to 30 June 2026, covering late registration, late payment and late returns across VAT, corporate tax and other taxes.

UAE Advance Pricing Agreements: A Transfer Pricing Certainty Guide

An Advance Pricing Agreement lets a UAE business agree its related-party transfer pricing with the FTA in advance, fixing the arm's length method for three to five years and removing the risk of a later dispute.

UAE Transfer Pricing 2025: The Year TP Went Live in CT Filings

2025 was the year UAE transfer pricing became operational — embedded in corporate tax returns with mandatory disclosures, audit-ready Local and Master Files, and a direct link to Pillar Two minimum-tax outcomes.

Cabinet Decision No. 1 of 2026: UAE Sports Entity Tax Exemption

Cabinet Decision No. 1 of 2026 gives qualifying sports entities a UAE corporate tax exemption, applied retrospectively from 1 June 2023, provided five strict conditions are met.

OECD Pillar Two Side-by-Side Safe Harbours: 2026 Package

On 5 January 2026, 147 members of the OECD Inclusive Framework agreed a new Pillar Two package adding five safe harbours, including a Side-by-Side safe harbour that considers US minimum tax rules.

Intercompany Agreements: A UAE Transfer Pricing Essential

Intercompany agreements are mandatory transfer pricing documentation under UAE Corporate Tax. The FTA can request them in an audit, and they must be signed, priced at arm's length, and match actual conduct.

KSA Withholding Tax on Technical and Consultancy Fees

ZATCA's December 2025 bulletin sets withholding tax on non-resident fees: 5% on technical services, 15% on royalties, with treaty relief cutting KSA tax to nil where there is no permanent establishment.

TNMM Transfer Pricing: Four Benchmarking Pitfalls to Avoid

The Transactional Net Margin Method tests related-party margins against comparables, but four errors in the FAR analysis, tested party, PLI and data routinely make TNMM benchmarks indefensible.

Transfer Pricing for Intangibles: The DEMPE Framework

Transfer pricing for intangibles turns on DEMPE: which group entity develops, enhances, maintains, protects and exploits the asset and bears the risk. Substance, not legal title, decides who earns the return.

Why UAE Businesses Must Register on the goAML Portal

UAE DNFBPs and financial institutions must register on the goAML portal run by the Financial Intelligence Unit. Non-registration risks fines from AED 50,000 to AED 1,000,000 and suspension of the trade licence.

Distribution Models in Transfer Pricing: FFD, LRD and Agent

A distributor's transfer pricing profit must match its real functions and risks: full-fledged distributors earn entrepreneurial margins, while limited-risk distributors and commission agents earn routine returns.

UAE Tax Procedures Law 2026: What Decree-Law 17 of 2025 Changes

Federal Decree-Law No. 17 of 2025 amends the UAE Tax Procedures Law from 1 January 2026, introducing a strict 5-year limitation on tax credits and refunds, simpler error corrections and binding FTA directives.

UAE Tax Restructuring: Models and Business Restructuring Relief

With UAE corporate tax, transfer pricing and substance rules in force, groups are restructuring to preserve free zone benefits, fix entity mischaracterisation and access tax-neutral Business Restructuring Relief.

FTA Decision No. 9 of 2025: When the FTA Can Withhold Tax Refunds

FTA Decision No. 9 of 2025 lets the Federal Tax Authority decline refunds of residual VAT, Excise and Corporate Tax during a tax audit, where returns are outstanding or evasion is suspected, from 1 January 2026.

UAE Corporate Tax: Key Decisions Shaping FY 2025-26

A wave of Ministerial, Cabinet and FTA decisions effective from 2025 reshapes UAE corporate tax groups, participation exemption, Pillar Two, non-resident nexus and fund rules for the FY 2025-26 filing cycle.

Cost Contribution Arrangements Under UAE Transfer Pricing

A cost contribution arrangement lets group companies share the costs and benefits of jointly developing assets or services. Under UAE rules, each participant's contribution must match its expected share of the benefit.

How Tax Technology Strengthens UAE Compliance and Risk

Tax technology moves UAE compliance from periodic filing to real-time data management. SBC's TaxMate automates corporate tax computations, transfer pricing documents and audit-ready records to cut errors and manage risk.

Saudi Arabia RHQ Programme: Licensing Rules and 0% Tax

Saudi Arabia's RHQ Rules, under Cabinet Resolution No. 338, give licensed regional headquarters a 0% corporate income tax and 0% withholding tax regime for 30 years, subject to strict substance and activation tests.

UAE QFZP Framework: Ministerial Decision 229 of 2025 Explained

Ministerial Decision No. 229 of 2025 rewrites the UAE's free zone activity rules, retrospective to 1 June 2023, broadening qualifying commodities and treasury income while tightening the 51% distribution test.

Royalty Payments in Transfer Pricing: Arm's Length Rates

Royalty payments between related parties must be set at an arm's length rate and backed by benchmarking, DEMPE analysis and a benefit test. Weak documentation is the most common reason royalty deductions are challenged.

FTA Decision 7 of 2025: Audited Accounts for UAE Tax Groups

FTA Decision No. 7 of 2025 requires UAE Corporate Tax groups to prepare, audit and file aggregated financial statements, combining the parent and subsidiaries, within nine months of the tax period end.

Ministerial Decision 173: UAE Fair-Value Property Depreciation

Ministerial Decision No. 173 of 2025 allows an elective tax depreciation deduction on IAS 40 fair-value investment properties, restoring parity with historical-cost taxpayers.

UAE Interest Deduction Limitation Rules: The 30% EBITDA Cap Explained

The UAE caps a business's net interest deduction at the higher of 30% of adjusted EBITDA or an AED 12 million de minimis threshold, with a separate specific rule that can disallow related-party interest in full.

Cabinet Decision No. 35 of 2025: UAE Non-Resident Nexus Rules

Cabinet Decision No. 35 of 2025 extends the UAE non-resident nexus to foreign investors in Qualifying Investment Funds and REITs, applying to tax periods from 1 January 2025.

Ministerial Decision No. 84 of 2025: Who Needs Audited Accounts

Ministerial Decision No. 84 of 2025 sets who must keep audited financial statements for UAE Corporate Tax: businesses over AED 50 million revenue, all Qualifying Free Zone Persons, and every Tax Group.

Advance Pricing Agreements in Saudi Arabia: How ZATCA's APA Works

An Advance Pricing Agreement lets a Saudi taxpayer agree its transfer pricing method with ZATCA in advance. ZATCA currently offers only unilateral APAs, for transactions of at least SAR 100 million a year.

UAE Pillar Two and DMTT: How the 15% Top-Up Tax Works

The UAE's Domestic Minimum Top-up Tax (DMTT) charges large multinational groups a 15% minimum effective tax rate in the UAE for financial years starting on or after 1 January 2025.

UAE Ministry of Finance Pillar Two Guidance: What It Means

The UAE Ministry of Finance's Pillar Two Guidance Document, issued 8 February 2025 and effective from 1 January 2025, sets out how the UAE applies the OECD 15% global minimum tax to MNE groups over EUR 750 million.

Free Zone Tax Regimes Under UAE Corporate Tax — What Qualifying Income Really Means

With the UAE Corporate Tax law now fully in force, free zone entities face a critical question: does your income actually qualify for the 0% rate? We break down the substance requirements, income tests, and common pitfalls.

UAE Tax Group Registration: The 31 December 2024 Deadline

UAE businesses that want to form a Corporate Tax group for a January to December 2024 tax period must file a joint application with the FTA by 31 December 2024, with every member resident and sharing the same tax period.