GCC Fintax

Contribution by Nilesh Patel

UAE

FAQs on the UAE Transfer Pricing Regulations (December 2022)

Nilesh Patel on 05 January 2023
The UAE Federal Tax Authority released on 9 December 2022 Federal Decree-Law No. 47 of 2022 (Taxation of Corporations and Businesses). That Decree-Law contains ..

Taxation of Digital Businesses - Pillar 2 Proposals of OECD

Nilesh Patel on 30 August 2021
Part II (Pillar 2) [This Article on Taxation of Digital Businesses - Pillar 1 and 2 Proposals of OECD is presented in two parts. Here, Part II is presented. ..

Taxation of Digital Businesses - Pillar 1 Proposals of OECD

Nilesh Patel on 26 August 2021
Part I (Pillar 1) 1. Opening Imagine Google derives Revenue of USD 100 million from your Country. But Google has no physical presence in your Country. No ..

BEPS Action 5: Countering Harmful Tax Practices More Effectively, Taking into Account Transparency and Substance

Nilesh Patel on 16 May 2021
Preferential Tax Regimes, providing for no or low taxation, implemented by certain Countries can induce MNCs to artificially shift profits to those Countrie..

Selection of Most Appropriate Transfer Pricing Method

Nilesh Patel on 23 March 2021
HOW TO SELECT THE MOST APPROPRIATE TRANSFER PRICING METHOD? 1. Introduction Under Transfer Pricing Bylaws of Saudi Arabia (KSA) - and most of the Countrie..

Attribution of Profits to Permanent Establishments

Nilesh Patel on 26 January 2021
How do you Attribute Profits to a Permanent Establishment? 1. Opening In BEPS Action 7 the OECD has recommended changes to Tax Treaties to prevent Artific..

Management Service Fees - Transfer Pricing Aspects

Nilesh Patel on 19 January 2021
How to defend your Management Service Fees Payment in Transfer Pricing Audits? 1. Background 1.1. The payment of Management Service Fees (MSF) is a necess..