The UAE’s tax landscape has changed materially: a 9% corporate tax, a Domestic Minimum Top-up Tax for in-scope MNEs, transfer pricing obligations aligned with the OECD Guidelines, and a treaty network of over 130 jurisdictions now sit on top of what used to be a no-tax baseline.
Cross-border structures that worked five years ago can leak tax, fail substance tests or attract Pillar 2 top-up. We help businesses tighten those structures so they hold up commercially and under scrutiny.
Structuring and Treaty Access
Inbound and Outbound Structuring
Investment structuring for businesses entering the UAE and UAE groups deploying capital abroad: holding company location, free zone versus mainland positioning, QFZP eligibility, repatriation routes and exit planning: that survives substance tests and uses treaty benefits without triggering anti-abuse rules.
Foreign Entity UAE Compliance
Advising non-resident companies and foreign groups on UAE corporate tax and VAT registration, FTA filing obligations and UBO disclosure, even without a permanent establishment, and flagging where activity crosses into taxable presence.
DTAA, TRC and Treaty Access
Securing Tax Residency Certificates from the FTA, building the substance file that supports a treaty claim, and applying the correct treaty to dividends, interest, royalties, capital gains and business profits across the UAE’s 130-plus double taxation agreements.
Permanent Establishment Risk
PE assessments under the Corporate Tax Law and relevant treaties covering fixed place of business, dependent agents and service PE thresholds, evaluating cross-border activities to identify exposure and align operational structures to mitigate unintended risk.
Transfer Pricing and Global Minimum Tax
Transfer Pricing
Policy design and documentation aligned with Article 34 and the OECD Guidelines: Master File, Local File, benchmarking, intercompany agreements and the related party disclosure form: plus support drafting and filing Advance Pricing Agreements with the FTA.
Pillar 2 Global Minimum Tax
Scope assessment, FTA registration support and Effective Tax Rate computation under Cabinet Decision No. 142 of 2024, which applies a Domestic Minimum Top-up Tax to MNE groups with consolidated revenue of EUR 750 million or more from financial years starting on or after 1 January 2025.
Cross-Border Flows and Mobility
Withholding Tax
Assessing applicable treaty provisions and domestic laws to determine withholding tax outcomes on cross-border transactions, ensuring arrangements meet treaty eligibility conditions such as beneficial ownership and substance.
Foreign Tax Credits
Evaluating the availability and utilisation of foreign tax credits in cross-border transactions and for cross-border employees, analysing domestic laws, treaties and Multilateral Instrument provisions to support compliant positions.
Founder and Executive Mobility
Pre-immigration planning for founders and HNIs relocating to or from the UAE: residency transitions, origin-country exit tax, asset realignment and ESOP and RSU positioning: plus secondment structuring and cross-border employee mobility for corporate clients.
How We Work
Engagements are partner-led and staffed by chartered accountants and international tax specialists with experience across UAE, Indian, US, UK and European tax regimes. Every engagement is scoped to the transaction, the treaty access position and the reporting timeline.