Rachel Fox

Biography

Rachel is an Irish qualified lawyer and chartered tax advisor with over 15 years’ experience on tax matters.

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Recent Experience

• Advising one of the largest investment firms in the Middle East on tax planning matters, including group restructurings, mergers and acquisitions across the GCC region, post-merger integration and Pillar Two planning.
• Advising a major international food group on the risks and potential optimisation strategies relating to corporate tax, VAT, customs and transfer pricing on its imports, manufacturing and sales operations in the UAE and KSA.
• Advising a sovereign wealth fund portfolio company on the tax implications of its proposed joint venture with a major development company, the associated financing arrangements, land transfers, and sales structure relating to a USD 2.8 billion mixed-use real estate development.
• Advising one of the largest logistics companies in the world on all tax implications arising from the introduction of corporate tax in the UAE, including the application of the Qualifying Free Zone Person regime, transfer pricing matters and Pillar Two.
• Advising a major construction services group on its regional tax matters across the GCC, including corporate tax, transfer pricing, withholding tax matters and assisting with a potential VAT related dispute.
• Advised a large regional project development company on the tax implications of its group restructuring including the impact of the new UAE corporate tax regime on its offshore operations
• Advised an EU-based private equity fund on the tax aspects of establishing holding company operations in the UAE including the interaction of the new UAE participation exemption regime with international hybrid entity structures.
• Advised a real estate investment fund on various tax compliance matters in the UAE, including VAT obligations for one of its development companies and FATCA/ CRS matters.
• Advised a major international hospitality resort operator on the tax implications of establishing operations in the UAE and KSA.
• Advised an international insurance company on underwriting specific tax risks on several M&A deals across the UAE, Qatar, and Saudi Arabia.
• Advised a prominent UK private education company on tax matters associated with its presence in the UAE and Qatar.
• Provided advice to a number of ultra-high net worth GCC family groups on tax matters, including restructurings, management of corporate tax and zakat risks on cross border investments and the tax implications of establishing various asset-protection structures.
• Advised several major international companies on redomiciling from various tax havens to the UAE, including advising on the ongoing tax implications of establishing holding companies in the UAE.