Articles

Bloomberg Tax

INSIGHT: Country-by-Country Reporting Consultation and the Importance to MENA Locations

The OECD issued a public consultation on Country-by-Country Reporting (CbCR) in February 2020. Shiv Mahalingham, of Deloitte MENA, summarizes some of the most important themes based on experience with CbCR in the Middle East, North Africa region.

Bloomberg Tax

INSIGHT: MENA Transfer Pricing—What MNEs Should Look Out for in 2020

Shiv Mahalingham, of Deloitte MENA, discusses key areas that multinational enterprises operating in Middle East, North Africa (MENA) should look out for in 2020 with respect to transfer pricing regulations, guidance and audits.

Bloomberg Tax

Insight: GloBE Pillar Two and the Potential Impact on MENA Transfer
Pricing

Shiv Mahalingham, of Deloitte, sets out a summary of the key proposals
for Global Anti-Base Erosion under Pillar Two and looks at the potential impact
on the Middle East, North Africa (MENA) region (a region that is at present
characterized by the introduction of new/revised transfer pricing regulations).

Bloomberg Tax

INSIGHT: International Transfer Pricing Cases—Their Application to Middle East, North Africa

Shiv Mahalingham, Deloitte transfer pricing Leader, considers how transfer pricing cases such as Amazon, Glencore and Fiat have influenced the transfer pricing regimes of the Middle East and North Africa.

Bloomberg Tax 

INSIGHT: Transfer Pricing Regulations in Saudi Arabia and Egypt—A Comparison

The Kingdom of Saudi Arabia (‘‘KSA’’) has introduced comprehensive transfer pricing bylaws (and guidance on how these should be interpreted). The other territory in the Middle East that has detailed transfer pricing regulations is Egypt. This Insight compares these two transfer pricing regimes in terms of the similarities and departures. This Insight will be helpful for multinational entities operating in the region and also for ministries of finance and tax authorities in the region who are soon to introduce transfer pricing regulations of their own.

Are exclusive distributors subject to new transfer pricing rules in KSA?

Summary document on main impacts and requirements

GAZT has recently released their final TP bylaws. Following this major tax development, Deloitte has created a summary document with our initial set of views. 

The ITR Energy Guide

Transfer pricing in the Middle East’s oil and gas sector

A collaborative publication with the International Tax Review’s 2019 Energy Guide

As resource-rich Middle Eastern governments suffer a decline in oil revenues, many governments are reforming transfer pricing (TP) regulations to limit capital flight. Deloitte’s Shiv Mahalingham, Alena Kovalova and Claire Boushell discuss the regional regulatory trends.

Bloomberg Tax

INSIGHT: International Taxation—Economic Substance and Economic Significance

There are many areas of statute, guidance and case law that have touched upon the issue of economic substance over the years (albeit not actually answering the question of how much substance is enough) and this article pulls some of these together into a handy summary reference guide for tax administrations and multinational corporations.

TP Week

Transfer Pricing has landed in the MENA region

The tax regulatory landscape in the Middle East and North Africa (MENA) is changing with several countries in the region joining the Base Erosion and Profit Shifting (BEPS) Inclusive Framework (IF) and committing to adopting the BEPS minimum standards. Moreover, Egypt, Saudi Arabia, Kuwait, Tunisia and the UAE are recent signatories of the multilateral instrument (MLI), which demonstrates the clear shift in the Middle East towards aligning tax regimes with international leading practices. Lebanon has also expressed intent to sign the MLI.

Bloomberg BNA

INSIGHT: Rolling out Country – by – Country Reporting in the Middle East, Africa

Shiv Mahalingham (Deloitte Transfer Pricing Head) talks about how International taxation is an evolving landscape in the Middle East and North Africa region. In recent years, we have witnessed a conscious movement to align tax regimes with international tax transparency trends and leading practices.

Bloomberg Tax

INSIGHT: BEPS Action 5 – Impact on the UAE

BEPS Action 5 focuses on no or low preferential corporate tax rate (preferential regimes) that can be classified as harmful tax practices. In November 2018, the Organization for Economic Co-operation and Development (‘‘OECD’’) issued a press release relating to BEPS Action 5 preferential regime reviews conducted by the Forum on Harmful Tax Practices (‘‘FHTP’’). This article discusses the press release and accompanying guidance (or ‘‘Global Standard Report’’) specifics before concluding on the likely impact on no or only nominal tax jurisdictions (‘‘NOONs’’) such as the United Arab Emirates.

Bloomberg Tax

INSIGHT: Foreign Direct Investment Opportunities for Multinational Enterprises in the UAE

The commitment of the United Arab Emirates (UAE) to adopting the BEPS minimum standards in 2019 has solidified its position as a major regional hub for investment. The Organization for Economic Co-operation and Development (OECD) released a preferential regimes report on July 23, 2019 confirming that the UAE is in line with international tax standards (with one technical point being addressed at present).

Bloomberg Tax 

INSIGHT: Head to Head—OECD and UN Transfer Pricing Standards

A number of Middle East and North Africa (MENA) tax administrations are at present working on the design and implementation of new transfer pricing regimes. In looking at a new transfer pricing regime, it is important that one takes into account all international standards with respect to transfer pricing.

Bloomberg Tax 

INSIGHT: Interaction Between Transfer Pricing and Capital Transactions

Transfer pricing regulations are new to the Middle East and North Africa (MENA) region; however, we are already starting to see complex issues, challenges and opportunities relating to the definition of an arm’s length provision.