26.01.2026 Digest December 2025 – January 2026 Welcome to our latest digest, detailing the critical tax and regulatory developments across the UAE and GCC from December 2025 through January 2026. The new year has begun with significant OECD releases Pillar Two “Side-by-Side Package”: key updates on safe harbours and simplifications On 5 Jan 2026, the OECD/G20 Inclusive Framework released the Pillar Two “Side-by-Side Package” as Administrative Guidance to the Global Anti-Base Erosion (GloBE) Model Rules, intended to be incorporated into 09.12.2025 Pillar Two meets CFC rules: how far DMTTs in the GCC go in recognizing CFC taxes? In the attached slides, we look at: How Covered Taxes linked to CFC inclusions are allocated back to the Constituent Entity under the GloBE Model Rules How Qatar and Kuwait 28.11.2025 Split ownership and minority shareholding under Pillar Two The introduction of the GloBE rules under Pillar Two has forced groups with split ownership chains and partially owned intermediaries to reconsider long-settled assumptions about how much low-taxed income can, 27.11.2025 New Amendments to Administrative Penalties under Cabinet Decision No.129 of 2025 The Cabinet Decision No. 129 of 2025 has been approved and it introduces a unified Administrative Penalty framework under the Tax Procedures Law, consolidating the previously separate regimes for Corporate 07.11.2025 Updates to UAE Vat Input Tax Apportionment Guidance The Federal Tax Authority (FTA) has issued a revised Input Tax Apportionment Guide (VATGIT1, September 2025), which replaces the previous version dated March 2023. The updated guide reflects the amendments 26.09.2024 APAC Legal Awards 2024: PGP Tax Consultancy is your most reliable partner in the field of tax legislation in the Middle East According to the international legal rating APAC Legal Awards 2024, PGP Tax Consultancy has been proclaimed the “Most Reliable Tax Partner 2024 – Middle East”. PGP Tax Consultancy offers a 23.05.2024 PGP Tax Consultancy has celebrated its first anniversary in Dubai On 16 May, we held an evening function in Dubai to commemorate the first anniversary of the official launch of PGP Tax Consultancy. Senior Partner Andrey Nikonov and Partner 11.03.2024 PGP Tax Consultancy is among the leaders in the Pravo.ru rating dedicated to the UAE market PGP Tax Consultancy has been ranked in group I of the Pravo.ru ranking in the Tax Law category. Pravo.ru’s analysts have assessed the Russian law firms working on the UAE Show more 1 2
