International desk
Two countries, one set of facts, two tax authorities.
Cross-border structuring, treaty positions and permanent establishment risk for groups that operate in more than one jurisdiction and are taxed in each of them differently.
- Treaty network
- 140+ UAE treaties
- Pillar Two
- Readiness reviews
- Coverage
- UAE, GCC and Egypt
- Deliverable
- Written technical position
Who this is for
If your business crosses a border, so does the exposure.
A person working remotely, a warehouse, or a manager who signs contracts abroad can each create a taxable presence nobody intended.
Map your exposure- Groups with subsidiaries outside the UAE
- Businesses with staff working from another country
- Companies receiving or paying cross-border royalties
- Entities needing a tax residency certificate
- Large groups approaching the Pillar Two threshold
- Founders relocating a holding structure
How the engagement runs
Four stages, one defensible position
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Map
Where you are taxed
Entities, people and contracts mapped against each jurisdiction that could claim a share.
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Test
Treaty and PE analysis
Which treaty applies, whether relief is available, and where a permanent establishment may already exist.
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Plan
Structure the answer
Options costed across all jurisdictions at once, because a saving in one is often a charge in another.
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Document
Write it down
A written position with the reasoning and references, so it survives review by either authority.
Scope of work
What the engagement covers
Where local advice is needed in the other country, we coordinate it rather than guess at it.
- Cross-border structuring
- Double tax treaty positions
- Permanent establishment reviews
- Tax residency certificates
- Pillar Two readiness
- Group reorganisation relief
Inside this line
What sits under International & Tax Planning
12 services on this desk. Most engagements use two or three of them.
Country-by-Country Reporting (CbCR)
Group reporting once you cross the threshold
Ask about thisPermanent Establishment Advisory
Whether your activity creates a taxable presence
Ask about this
Substance
Where the decisions are actually taken
Cross-border planning fails on the same point every time: the structure says one country and the people say another. Tax authorities look at where staff sit, where contracts are signed and where decisions are made.
We test the position against how the business actually runs before it is documented, because a file written to describe something that is not happening is worse than no file.
Documentation
Written before the year, not after it
Transfer pricing documentation prepared to explain last year's numbers carries less weight than a policy that set them. The first is a justification; the second is a position.
We set the policy, benchmark it, then keep the master and local files current as the group changes, so the file is never reverse-engineered from a result.
Files kept current Reviewed each year and on group change
Before we advise
What a cross-border question needs
An international position taken without the contracts is a guess. These make it an opinion.
- Group structure chart with jurisdictions
- Intercompany agreements in force
- Where staff and decisions physically sit
- Revenue split by counterparty country
- Existing tax residency certificates
- Any rulings or positions taken abroad
Where it goes wrong
Three things we are asked to fix most
Not theory. These are the ones that arrive as a problem rather than a question.
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01
Assuming a treaty applies
Treaty benefit depends on residency, substance and the article in question, tested separately.
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02
Permanent establishment by accident
One person concluding contracts abroad can create a taxable presence nobody planned for.
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03
Transfer pricing documented after the fact
A policy written to explain last year's numbers is worth less than one that set them.
Questions we get weekly
International tax, answered plainly.
It can be. Whether it creates a taxable presence depends on what that person does: someone concluding contracts is a very different case from someone answering email, and on the treaty in play.
No. Most treaties require substance and a residency certificate, and several have anti-abuse tests. Incorporation alone has not been enough for some years now.
Only very large groups are, and the threshold is measured on consolidated revenue over multiple years. Most businesses that ask us this turn out to be well below it, which is a short and free answer to give.
Related
Usually engaged alongside
Talk to the international desk
Tell us which countries you touch.
We will sketch where you are likely taxed and what is worth looking at properly. Thirty minutes with a partner, no charge.