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Transfer Pricing

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ZATCA has published the Regional Headquarters Tax Rules (“RHQ Tax Rules”), approved and enacted by ZATCA’s board resolution no. (9-1-24) on 04/02/2024. Under the RHQ Tax Rules, RHQ licensed entities will enjoy the following tax incentives for a period of 30 years commencing from the date on which the RHQ license is issued: 0% income tax on eligible Income (i.e. income from the main activities that an RHQ entity is allowed to carry out pursuant…

Over the course of past weeks, the General Authority of Zakat and Tax (ZATCA) has released a number of public consultations outlining the proposed amendments to a series of tax legislations. As an overall comment, this is a welcoming move and should be closely monitored as and when the proposed amendment is formally introduced in the relevant legislation. Below is a high-level summary of the proposed amendments to the relevant tax legislations in KSA. Consistent…

In brief Key highlights The issuance of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses (“Corporate Tax law”) on 9th December 2022, provides businesses operating in the UAE with a framework for understanding how the corporate tax regime will impact their business model. The Corporate Tax law is broadly in line with the public consultation document that was issued in April 2022, however, one of the notable changes is the release of…

In brief Across the globe, transfer pricing disputes have increased following a waterfall of changes, e.g., BEPS, increased transparency, global compliance obligations, intangibility of value creation and digitized taxation. The pandemic added its synchronized impact by provoking countless economic and social ripples on the already turbulent waters. Against this backdrop, the Middle Eastern economies are battling lower oil prices and budget deficits, which in turn increase the pressure for fiscal receipts. In the last couple…