Tax Law and International Tax Law

Intra-group financing is a key area of international taxation, involving financial transactions between related companies across jurisdictions. A parent company may provide a loan to a subsidiary, or one subsidiary may provide financing to another group company. Because these transactions take place between related parties, the terms and conditions of the financing must be consistent with the Arm’s Length Principle.

The UAE Federal Tax Authority has issued Corporate Tax Public Clarification CTP010, fundamentally changing how businesses must identify directors and officers for tax purposes.

The UAE Federal TaxAuthority (FTA) has recently issued Public Clarification CTP011¹, setting out its position on downward transfer pricing (TP) adjustments made by a Taxable Person in the Corporate Tax Return, along with the disclosure and documentation expected to support such adjustments.

Intra-group financing is a key area of international taxation, involving financial transactions between related companies across jurisdictions. A parent company may provide a loan to a subsidiary, or one subsidiary may provide financing to another group company. Because these transactions take place between related parties, the terms and conditions of the financing must be consistent with the Arm’s Length Principle.

تُعد الاتفاقية النموذجية لمنظمة التعاون الاقتصادي والتنمية (OECD Model Tax Convention on Income and on Capital) المرجع الأساسي الذي تستند إليه غالبية اتفاقيات تجنب الازدواج الضريبي المبرمة بين الدول، كما تمثل ال.

A UAE Family Foundation is not automatically exempt from Corporate Tax. However, it may elect to be treated as tax transparent under Article 17 if it satisfies the Federal Tax Authority’s conditions. The latest guidance clarifies how this applies to trusts, holding structures, asset transfers and family offices.

Most investors enter the Kingdom expecting a red carpet of tax breaks, only to realize that the real value isn’t a single blanket incentive, it’s a complex puzzle. While investment incentives in Saudi Arabia are world-class, they are not universal. The gap between a standard MISA license and a high-yield strategic entry lies in knowing which benefits are automatic and which require rigorous, program-specific applications.

Investors approaching the UAE market tend to encounter a free zone in UAE early because of streamlined registration, full foreign ownership, complete foreign ownership rights, full repatriation of profits and capital, and tax advantages such as no personal income tax and, in many cases, 0% corporate tax for qualifying businesses. Over time, UAE free zones have become embedded in how businesses and investment structures are built across the region, attracting both foreign investors and international businesses.

The Council of Ministers has approved significant tax relief measures for private universities, colleges, and institutes in Iraq, offering exemptions from penalties and additional charges on income tax and withholding tax obligations. These exemptions range from 50% to 100% depending on how quickly institutions settle their principal tax liabilities and complete mandatory tax reconciliation procedures within specified timeframes.

تُعد الاتفاقية النموذجية لمنظمة التعاون الاقتصادي والتنمية (OECD Model Tax Convention on Income and on Capital) المرجع الأساسي الذي تستند إليه غالبية اتفاقيات تجنب الازدواج الضريبي المبرمة بين الدول، كما تمثل ال.

The OECD Model Tax Convention on Income and on Capital constitutes the primary reference upon which most bilateral tax treaties for the avoidance of double taxation are based. The accompanying OECD Commentaries serve as an essential interpretative source for understanding the meaning and application of the Convention’s provisions.

With the expansion of international business activities and investments, determining tax residency has become an important matter for individuals and companies that have transactions or sources of income in more than one country.