Al Tamimi & Company is the first law firm to establish an international tax practice focused on the Middle East region.

Our Tax Practice provides and coordinates cross border tax advice to leading multinational corporations, banks, financial institutions, governments, sovereign wealth funds, private equity groups, investment funds, real estate investment houses, family offices, joint ventures and other local, regional and international organisations.

Our clients operate in a wide range of industries including financial services, real estate, investment management, oil &gas, construction, infrastructure, telecommunications, media & entertainment, aerospace and defence, technology, healthcare, consumer goods and energy & utilities.

Our Expertise

Inbound & Outbound Tax Advisory 

• Structuring inbound investments and activities of multinational companies into the Middle East region from a tax perspective
• Advising on local tax implications and tax efficient establishment and conduct of business operations in the region
• Coordinating and managing cross border tax advice for large groups based in the region for their global investments across all asset classes and international acquisitions particularly across Europe, Americas and Asia Pacific regions

International Tax Structuring & Planning

• Advising on tax optimal corporate group structure, holding structures, financing, intellectual property planning, leasing and other tax planning techniques
• Advising on tax implications of expansion into new territories
• Tax optimisation strategies for your business model
• Tax efficient profit repatriation from overseas territories to parent company jurisdiction and withholding tax mitigation
• Double tax treaty issues
• Managing foreign permanent establishment risks
• Advising on global tax developments and obligations including measures under the Organisation for Economic Cooperation and Development (“OECD”) base erosion and profit shifting (“BEPS”) initiative, Foreign Account Tax Compliance Act (“FATCA”) and Common Reporting Standard (“CRS”)

Value Added Tax

• Analyse the VAT implications and risks of specific transactions
• Advising on VAT efficient transaction structuring of supply chain and developing strategies to reduce the VAT cost
• Advising you on your VAT compliance obligations and reviewing your VAT returns

Corporate Tax & Zakat

• Advising on the applicability of corporate tax or Zakat to your organisation
• Advising on tax aspects of structured finance transactions (including Islamic Finance)
• Advising on the availability of special tax incentives or exemptions
• Advising on the application of withholding tax and tax retentions

Tax Risk Management

• Provision of written tax opinion to enable you to defend your position
• Reviewing and drafting business contracts (including intercompany agreements) to minimise tax risk from a corporate tax, transfer pricing, VAT and withholding tax perspective
• Performing a tax health check to assess tax profile, compliance status and potential tax risks arising from your business operations
• Developing a tax risk management framework and strategy aligned with your corporate and business objectives
• Provision of tax training to enable you to develop inhouse tax knowledge and capability and allow you to manage tax risk

Transfer Pricing

• Analysing inter-company transactions to identify tax risks
• Developing a global transfer pricing policy and strategy for your business
• Tax efficient supply chain management including restructuring operating model and minimising transfer pricing risks
• Preparing benchmarking studies to evaluate the arm’s length nature of inter-company transactions
• Developing global and country specific transfer pricing documentation based on OECD guidelines including assistance with master file and country by country reporting in line with BEPS recommendations
• Negotiating advance pricing agreements with tax authorities and assistance with resolving transfer pricing disputes

Mergers & Acquisitions Tax

• Purchaser and vendor tax due diligence to identify any potential tax issues/risks and hidden tax liabilities
• Tax efficient transaction structuring of mergers, acquisitions, disposals, reorganisations, joint ventures both inbound into the region and internationally and advising on the related tax risks and consequences
• Exit tax planning
• Tax input into the sale and purchase agreements and negotiating tax clauses on your behalf with other party’s advisors

Other Indirect Taxes

• Advising on the applicability of customs duties and related procedures and developing strategies to optimise supply chain structures for customs purposes
• Advising on and assistance with obtaining customs duties relief, exemptions and deferral where applicable
• Analysing the applicability of excise tax to your business and advising on tax efficient structures
• Advising on and assistance with excise tax compliance obligations

Tax Ruling, Disputes & Litigation

• Applying to the tax authority for a ruling to clarify or confirm the tax treatment of a specific transaction or arrangement
• Representing your organisation before, and negotiating on your behalf with, tax authorities in complex tax audits, disputes and investigations
• Tax appeals and litigation support

Tax Policy

• Advising governments and tax authorities on developing tax policy, tax reform. introducing new taxes and implementation of taxes
• Drafting and advising on new tax legislation
• Advising and training tax authorities on application of tax laws as well as tax enforcement and collection

For more insight on tax issues across the region make sure you watch our videos, Part One and Part Two.