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. 20.02.2026 VARA as a “Competent Authority” for UAE Free Zone Corporate Tax: the opening for Dubai virtual-asset wealth managers and the unresolved family-office edge case The Free Zone Corporate Tax regime was drafted with a familiar instinct: where the activity is, in substance, regulated financial intermediation, the 0% rate should be available (subject to the 16.02.2026 Cabinet Decision No. (1) of 2026 on Exempting Certain Sports Entities from Corporate Tax On 9 February 2026, the UAE Ministry of Finance announced the issuance of Cabinet Decision No. (1) of 2026, introducing a Corporate Tax exemption for certain sports entities, which are Show more 1 2 … 18
