International Tax and Transfer Pricing

There are around 140 countries of the world who have committed to implement the Tax related recommendations of the Organization for Economic Cooperation and Development (OECD) in matters of Double Taxation, Transfer Pricing and VAT. We are well versed in advising on the most optimal business models across multiple countries that benefit from double taxation relief, tax arbitrage, preferential tax regimes and mitigation of transfer pricing risks.

01. Our Comprehensive Suite of International Tax and Transfer Pricing Services

Our International Tax and Transfer Pricing services encompass a broad spectrum of offerings, designed to cater to the unique needs of businesses and individuals operating on a global scale. Here are some of the services provided by our international Tax professionals:

Global Tax Strategy Development

We have the requisite experience of crafting tax strategies aligned with business goals and cross-border considerations. We have specialized expertise to carve strategies aimed at optimizing a company’s tax position across multiple jurisdictions through streamlining of legal structures for tax efficiency.

Transfer Pricing

One of the biggest challenges in today’s technology disrupted world of international business is placing tax-compliant values on the intercompany transactions and attribution of multi-jurisdictional profits to each constituent entity operating in sync as a multinational group. In this regard, rules and regulations established by OECD as well as member countries’ domestic authorities have provided ample guidelines on matters of arms length, profit attribution to group entities and permanent establishments. In case of tax conflicts, there is ample case law available to advise on transfer pricing grievances. We carry superb expertise in advising on optimal transfer pricing solutions and resolutions to challenges and conflicts of transfer pricing.

Foreign Investment Guidance

Groups expanding to new geographical segments find it necessary to engage us for assisting with tax implications related to investments abroad. We combine the doctrines of business and financial management with our experience of regional tax framework, knowledge of corporate law and other qualitative and quantitative factors to advise on investment decisions across multi-jurisdictional supply chains.

Economic Substance Reporting (ESR)

The Economic Substance Regulations (ESR) in the UAE, Qatar and Bahrain require companies, including those in free zones, to maintain an adequate ‘economic presence’ in the country if they engage in any of the defined ‘relevant activities. These regulations were introduced to honor the UAE’s commitment as a member of the OECD Inclusive Framework on Base Erosion and Profit Shifting (BEPS). We offer ESR Impact Assessment and compliance support in UAE, Qatar and Bahrain, which are the only GCC countries with ESR compliance requirements.

Country by Country Reporting

As a member of the Organization for Economic Cooperation and Development (OECD) Inclusive Framework on Base Erosion and Profit Shifting (BEPS), all GCC countries have committed to implementing BEPS Action 13, related to transfer pricing documentation and Country-by-Country (CbC) reporting except Kuwait, which has yet to implement CbCR. Each constituent entity of a Multi-National Enterprise (MNE) group, which is tax resident in the GCC State, is required to notify the competent authority (e.g. FTA or ZATCA) that it is the entity responsible for filing the CbC report. We support the CbCR compliance in a manner that avoids misreporting and mitigates the risk of penalty incurrence.

02. Our International Tax Credentials

We have advised sizable groups from USA, Europe and South Asia in technology, consumer, and B2B traders and have come up with out-of-box strategies that saved fortunes for our clients.

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Leadership

Muhammad Altaf Hussain

Head of Consultancy and Tax Division
altaf@szca.ae
+971 50 971 7890

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