The Tax Point

The UAE Ministry of Finance has issued Cabinet Decision No. (1) of 2026, expanding Corporate Tax exemptions under Federal Decree-Law No. 47 of 2022 to include certain qualifying sports entities. This reflects the UAE’s continued commitment to: • Supporting sustainable growth in the sports sector • Strengthening regulations for non-profit and sector-specific organizations • Clarifying eligibility and compliance requirements Sports clubs, federations, and related entities should review the updated framework to ensure alignment and maximize benefits. #CorporateTax #UAE #SportsSector #TheTaxPoint #TaxExemption #RegulatoryUpdate

🌿 Operating with clarity, even in uncertainty This week, our team is working from Kuala Lumpur, Dubai, Delhi and Rabat. Different continents, time zones, yet the same level of focus, care and attention to what we deliver. We create the conditions for our people to feel valued, understood and cared for. And from there, dedication and consistency naturally follow in how we work, and in what we deliver. For our clients, this translates into continuity, technical excellence and sustainable outcomes. The Tax Point

The UAE has introduced a structured R&D Tax Credit regime under Cabinet Decision No. 215 of 2025 and Ministerial Decision No. 24 of 2026, effective for tax periods starting 1 January 2026. The framework provides an expenditure-based tax credit ranging from 30% to 50% on qualifying R&D activities, along with defined caps and carry-forward mechanisms. As the regime takes shape, businesses will need to focus on: • Clearly linking activities to UAE-based R&D • Implementing robust tracking of eligible expenditure • Ensuring alignment with substance and operational footprint Early preparation will be key to securing and sustaining the benefit. #TheTaxPoint #UAE #R&D #TaxIncentives #Innovation #TaxStrategy #InternationalTax #MiddleEast #BusinessPlanning

𝗧𝗲𝗺𝗽𝗼𝗿𝗮𝗿𝘆 𝗿𝗲𝗺𝗼𝘁𝗲 𝘄𝗼𝗿𝗸 𝗮𝗯𝗿𝗼𝗮𝗱: 𝗔 𝗣𝗲𝗼𝗽𝗹𝗲 𝗱𝗲𝗰𝗶𝘀𝗶𝗼𝗻 𝘄𝗶𝘁𝗵 𝘀𝘁𝗿𝘂𝗰𝘁𝘂𝗿𝗮𝗹 𝗰𝗼𝗻𝘀𝗲𝗾𝘂𝗲𝗻𝗰𝗲𝘀 Allowing employees to work remotely from abroad may be the right decision from a people perspective. But it is not a neutral one from a tax and legal standpoint. Across the Middle East, organisations are currently navigating these decisions in response to regional uncertainty. What appears to be a temporary and pragmatic solution can quickly create lasting cross-border implications. Recent developments under the OECD Model Tax Convention (Article 5) reinforce this point. A home office used on a continuous basis for business activities may, in certain circumstances, constitute a permanent establishment. From a tax perspective, the implications are immediate: - Permanent establishment exposure in the host country - Employee-level taxation triggered by physical presence - Local payroll, withholding, and reporting obligations - Potential shifts in social security contributions and cost structures The traditional reliance on the 183-day rule is increasingly insufficient in remote work scenarios. Substance, continuity, and the nature of activities now carry more weight than simple day counting. Beyond tax, the complexity extends further: - Immigration and work authorisation constraints - Local labour law implications - Misalignment of benefits, insurance, and pension coverage 𝗧𝗵𝗲 𝗧𝗮𝘅 𝗣𝗼𝗶𝗻𝘁 𝗽𝗲𝗿𝘀𝗽𝗲𝗰𝘁𝗶𝘃𝗲 At The Tax Point, we approach these situations differently. Not as isolated tax risks, but as questions of structure, substance, and defensibility. We work with leadership teams to: - Map value creation vs. physical presence - Assess PE exposure under evolving OECD interpretation and Double Tax Treaties - Align tax, legal, and operational positioning - Design practical, defensible frameworks If you are currently managing temporary relocations or remote work arrangements, this is the moment to step back and assess the structural implications. Happy to discuss and challenge your current setup. #TheTaxPoint #InternationalTax #TransferPricing #PermanentEstablishment #OECD #RemoteWork #TaxStrategy #MiddleEast

On 23 January 2026, the Federal Tax Authority released Version 2.0 of the Taxpayer User Manual for the reactivation of Corporate Tax TRNs via the EmaraTax portal. This update introduces a structured and fully digital process for reactivating previously deregistered Corporate Tax registrations in the United Arab Emirates. Key features include: ✔️ A dedicated “Reactivate TRN” workflow within EmaraTax ✔️ A structured application process with mandatory completion steps ✔️ Pre-populated entity and activity data with limited amendments ✔️ Mandatory disclosure of tax period and business re-commencement date ✔️ Real-time tracking and full visibility on application status ✔️ Automated notifications throughout the process lifecycle Beyond the technical update, this reflects a broader trend. Tax authorities are increasingly embedding compliance directly into digital systems — reducing ambiguity, increasing traceability, and standardizing processes. For businesses, this means one thing: operational readiness is becoming as important as technical compliance. #TheTaxPoint #UAETax #CorporateTax #TaxCompliance #DigitalTax #InternationalTax

As the corporate tax framework in the United Arab Emirates continues to mature, the Federal Tax Authority has introduced Advance Pricing Agreements (APAs) through the Corporate Tax Guide CTGAPA1. For multinational groups operating in the UAE, APAs represent an important step in strengthening tax certainty. By allowing taxpayers to agree in advance on the transfer pricing methodology applicable to specific related-party transactions, this mechanism can significantly reduce transfer pricing uncertainty and help mitigate potential disputes during future tax audits. In our latest brief, we explore the key features of the UAE APA framework and what they mean for businesses managing cross-border transactions. 👉 https://lnkd.in/g3Bx8_gQ #TransferPricing #UAETax #InternationalTax #TaxGovernance #TheTaxPoint

Saudi Arabia has recently officially approved the regulatory framework for several Special Economic Zones, including Jazan, King Abdullah Economic City, and Ras Al-Khair, alongside the Cloud Computing & IT SEZ. From a tax and customs perspective, this is a major development:  ✔️ Corporate Income Tax aligns with the Saudi system  ✔️ Zakat is excluded for licensed SEZ entities  ✔️ Potential Withholding Tax exemptions  ✔️ Zero-rated VAT on qualifying mainland-to-SEZ supplies  ✔️ Imports under customs suspension are VAT neutral ✔️ Customs duties suspended for eligible activities Detailed implementation guidance and economic substance requirements are currently under consultation. For businesses considering SEZ licensing, incentives alone don’t create value. ✅ Strategic structuring, operational substance, and careful planning are key to fully capturing the benefits. #TheTaxPoint #SaudiArabia #SEZ #TaxStrategy #InternationalTax #VAT #Customs #MiddleEast #Investment #BusinessPlanning

𝗧𝗿𝗮𝗻𝘀𝗳𝗲𝗿 𝗣𝗿𝗶𝗰𝗶𝗻𝗴 𝗖𝗼𝘂𝗻𝘁𝗿𝘆 𝗣𝗿𝗼𝗳𝗶𝗹𝗲𝘀 - 𝗧𝗵𝗲 𝗨𝗻𝗶𝘁𝗲𝗱 𝗔𝗿𝗮𝗯 𝗘𝗺𝗶𝗿𝗮𝘁𝗲𝘀 🇦🇪 We are pleased to launch a new series highlighting key transfer pricing developments across jurisdictions that matter for International Groups. In this first edition, we focus on the United Arab Emirates, where the introduction of Corporate Tax has significantly reshaped the transfer pricing landscape. From documentation requirements to practical enforcement considerations, understanding the UAE framework is now essential for multinational groups operating in the region. Each profile in this series will provide a concise, focused read overview of: • The regulatory framework • Key compliance expectations • Practical considerations observed in practice A useful reference point for tax leaders managing cross-border operations. #TransferPricing #UAETax #InternationalTax #TaxGovernance #TheTaxPoint https://lnkd.in/dgkYSxBB

Industry events bring together different formats, panels, discussions, and direct exchanges. What matters to us is the substance of the conversation: clarity of thought, relevance, and real engagement. That’s where we choose to invest our presence at The Tax Point. #TheTaxPoint #TaxAdvisory #ProfessionalServices #ClientFocus #IndustryDialogue

Software payments in Saudi Arabia are no longer an area where assumptions are safe and are now under heightned scrutiny. With ZATCA’s issued Guidelines under the Saudi Income Tax Law, the classification of software-related payments, particularly in cross-border arrangements, is subject to heightened scrutiny in practice.  📌 29 transaction types addressed  📌 Practical examples provided  📌 Direct implications for withholding tax exposure For multinational groups operating in KSA, this is not just a technical update, it is a structuring and risk management issue. Is your current software model aligned with the latest regulatory expectations? #SaudiArabia #KSA #InternationalTax #WithholdingTax #TaxRisk #TheTaxPoint #TransferPricing #ZATCA #CrossBorder