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 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 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 09.02.2026 Cabinet Resolution No. (209) of 2025 on Exchange of Information upon Request for Tax Purposes On 31 December 2025, the UAE issued Cabinet Resolution No. (209) of 2025, establishing an enhanced framework for the collection and exchange of information upon request for tax purposes. The Show more 1 2 … 16
