Middle East: Tax

For years, pricing between group companies in the UAE was more about practicality than policy. That approach has changed quickly and decisively. Today, the context of transfer pricing in the UAE is no longer limited to tax teams.

Corporate tax in Egypt is an essential element in the financial planning and regulatory compliance of local and international institutions.

تُعد الضرائب على الشركات في مصر عنصرًا أساسيًا في التخطيط المالي والامتثال التنظيمي للمؤسسات المحلية والدولية.

في إطار توجه الدولة المصرية نحو تطوير المنظومة الضريبية وتحقيق التوازن بين متطلبات ا...

In Egypt’s evolving transaction landscape, the ability to determine a reliable fair value and successfully execute deals increasingly depends on the effective integration of due diligence and valuation processes. As economic conditions become more complex characterized by inflationary pressures, currency volatility, and regulatory developments relying on standalone valuation models without thorough verification of underlying assumptions can lead to inaccurate conclusions. The interrelation between due diligence and valuation therefore represents a critical foundation for producing credible and defensible transaction outcomes.

The Federal Tax Authority (“FTA”) has issued Public Clarification CTP010, providing guidance on the meaning of “director” and “officer” for the purposes of the UAE Corporate Tax regime.

On 16 March 2026, Decision of the Council of Ministers No. 4 of 2026 entered into force. The Decision introduces a mechanism allowing the direct application of withholding tax rates under double tax treaties.

ZATCA has relaunched the Tax Penalties Exemption Initiative, effective January 1 to June 30, 2026, offering taxpayers a renewed opportunity to regularize their tax positions.

In December 2025, ZATCA has clarified the distinction between transfer of know-how/knowledge and technical or consultancy services which directly affects Withholding Tax (WHT) treatment.

Qatar's General Tax Authority has introduced new clarifications on capital gains tax, featuring a targeted exemption for intra-group restructuring transactions. These measures aim to streamline corporate reorganisation, improve asset management efficiency, and strengthen the country's investment climate while maintaining transparency in tax obligations.

In recent years, the international tax system has witnessed significant developments in tools and mechanisms aimed at enhancing transparency and curbing base erosion and profit shifting practices. These challenges have compelled countries to seek more effective means of regulating cross-border transactions. In this context, Advance Pricing Agreements (APAs) have emerged as an important mechanism that contributes to achieving greater tax certainty and reducing disputes between multinational enterprises and tax authorities regarding the arm’s length pricing of related-party transactions.

On 16 March 2026, Decision of the Council of Ministers No. 4 of 2026 entered into force. The Decision introduces a mechanism allowing the direct application of withholding tax rates under double tax treaties.