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17.03.2026

Pillar Two TP Adjustment Case Study

This case study isolates a timing tension that becomes visible only because Pillar Two is accounting anchored. A transfer price can be adjusted through a tax procedure long after the
16.03.2026

UAE March 2026 Crisis. Frustration, Force Majeure, and Hardship in the UAE.

The current situation in the UAE raises many questions and concerns. After the initial shock, there is inevitably a need to deal with reality. When it comes to legal issues,
11.03.2026

Cross-border remote work: foreign Permanent Establishment risk where an employee temporarily works abroad

This case study examines whether a company resident in the United Arab Emirates may be regarded as having created a permanent establishment in another State where it permits an employee
04.03.2026

Interest-free loan to a minority shareholder in the UAE: really no adjustment?

At first sight, the question seems almost rhetorical: if a UAE company grants an interest-free loan to its shareholder, surely the transaction is non-arm’s length and must trigger a tax

Substance during the emergency measures: force-majeure remote working and travel disruption

In “standard” compliance seasons, substance discussions are framed as design questions: where does the business truly operate, where are functions performed, and what level of people and asset footprint is
27.02.2026

Qualifying Group Relief on transfers to a newly incorporated subsidiary: when is the ≥75% own-ership condition met?

This case study considers whether the relief under Article 26 of the UAE Corporate Tax Law (the “Qualifying Group Relief” or “QGR”) can apply where a UAE resident company establishes
25.02.2026

Case Study: The “Flip‑Flop” 50% Home‑Working Threshold

Interpreting the OECD 2025 Update to the Commentary on Article 5 on Permanent Establishment Remote and hybrid working has forced a practical question into the centre of treaty PE analysis:
24.02.2026

Change of Individual Tax Residence: Case Study

This case study examines the application of the Principal Purpose Test (PPT) under Article 29(9) of the OECD Model Tax Convention in the context of a pre-disposal change of tax

Digest January – February 2026

Dear colleagues, We are pleased to present the next issue of our digest of tax and regulatory changes in the UAE and the Gulf countries for the period January–February 2026.