For groups operating across borders, UAE corporate tax is only one part of the picture. FinApt Group advises on Pillar Two, cross-border structuring, treaty relief and permanent establishment risk. For UAE groups expanding abroad and international groups operating in the UAE.
Pillar Two and Global Minimum Tax Advisory
For large multinational groups within scope of the OECD’s Pillar Two rules, we assess exposure, safe-harbour eligibility and reporting obligations under the UAE’s implementation of the global minimum tax framework.
FinApt experience: Pillar Two safe-harbour advisory delivered for a group in the investment and holding sector.
Cross-Border Tax Advisory
Advisory on the tax implications of operating, investing or transacting across more than one jurisdiction. That covers structuring, withholding tax exposure and coordination between UAE and foreign tax positions.
Double Tax Treaty Advisory
The UAE has double tax treaties with over 140 countries, including India, Pakistan, China, Egypt, Kuwait, Bahrain and Qatar. We help you determine whether treaty relief applies to your structure and how to claim it, reducing the risk of being taxed twice on the same income.
Permanent Establishment Advisory
Operating in a foreign market can create a taxable presence you didn’t intend. So can having foreign entities operate in the UAE. We assess permanent establishment risk before it becomes an exposure, and advise on structuring to manage it.
International Structuring
Advice on how to structure holding, financing and operating entities across jurisdictions in a way that is tax-efficient and compliant with UAE and international substance requirements.
International Tax Reporting and Compliance
Ongoing support for the reporting obligations that come with cross-border structures. Including coordination with Country-by-Country Reporting prepared alongside your transfer pricing documentation.
Why FinApt Group for International Tax
- International tax advisory delivered alongside transfer pricing and corporate tax, so cross-border structuring accounts for all three from the outset
- Experience with UAE, GCC and international holding structures
- Senior partners engaged directly on complex, cross-border mandates
Frequently Asked Questions
Does my business need to worry about Pillar Two?
Pillar Two generally applies to large multinational groups with consolidated revenue of EUR 750 million or more in 2 of the last 4 financial years. The UAE’s Domestic Minimum Top-up Tax applies a 15% rate for financial years starting on or after 1 January 2025. Most UAE businesses fall outside scope, but groups approaching that threshold should get an assessment done in advance.
What is a permanent establishment, and why does it matter?
A permanent establishment is a level of taxable presence a business can create in a country through its activities there, even without a registered entity. It triggers tax obligations in that country. Structuring and monitoring activity levels helps manage this risk.
Can double tax treaties reduce my tax bill?
Where the UAE has a treaty with the country you’re transacting with, treaty relief can reduce or eliminate double taxation on the same income. But relief has to be claimed correctly and supported with the right documentation.
How does international tax advisory relate to transfer pricing?
The two are closely linked. Cross-border structuring decisions directly affect your transfer pricing position, and CbCR reporting prepared alongside your transfer pricing documentation feeds into your international tax compliance. See our transfer pricing services.