ITR awards interview: Ramy Torbey of Eptalex

1 Eptalex was named Lebanon Tax Firm of the Year. What differentiated Eptalex in the eyes of clients and the market, and what does this recognition mean for the firm?

I think it comes down to one thing: we never advised on Lebanon in isolation. Our clients are families, banks and groups whose money, people and structures sit between Beirut, the Gulf and Europe, and their tax questions follow the same path. Having tax lawyers in Beirut, Abu Dhabi, Dubai, Riyadh, Milan and Istanbul working as one team means a Lebanese restructuring is designed from day one with the UAE, Saudi or European consequences already built in.

The other differentiator is that we stayed. Through the crisis, the Beirut team kept its senior people and kept doing complex work, at a time when many clients needed exactly that. The award recognises the Beirut practice, but it is really a recognition of the model: a Lebanese firm that chose to become a regional one. For us it is confirmation, not a finish line.

2 You earned recognition in the Transfer Pricing Practice Leader of the Year and Lebanon Lawyer of the Year categories. How have client expectations evolved over your career, and what has been occupying most of your attention recently?

Twenty years ago, clients wanted a technically correct opinion. Today, they want a decision. They expect us to understand their business, their family dynamics and the regulators in three jurisdictions, and to tell them what to do, in two pages, and to stand behind it.

The second shift is that governance and tax are now the same conversation. A family cannot plan succession without planning substance, residency and reporting. Recently my attention has been on exactly that intersection: cross-border family structures using ADGM [Abu Dhabi Global Market] and DIFC [Dubai International Financial Centre] foundations, the relocation of Lebanese and European wealth to the UAE, and intercompany arrangements for groups that have become multinational faster than their structures. The transfer pricing recognition reflects that last point. It is where tax, governance and commercial reality meet.

3 What challenges does transfer pricing in Lebanon and the wider region present, and where are you seeing the greatest scrutiny or demand?

The region moved from almost no transfer pricing rules to a full framework in a few years, and most groups have not caught up. In Lebanon, the challenge is reconciling arm’s length pricing with an economy where market data is thin, currencies have fractured and many intercompany arrangements were improvised during the crisis. The tax administration is now looking closely at management fees, royalties and financing flows between Lebanese companies and their Gulf affiliates, often years after the fact.

In the Gulf, the introduction of corporate tax in the UAE has turned transfer pricing from a Saudi topic into a regional one, and the free zone qualifying income rules add a layer that did not exist before. The demand we see is less for documentation and more for design: groups asking us to rebuild their intercompany model so that it is defensible in Beirut, Riyadh and Abu Dhabi at the same time, and consistent with where their people and decisions actually are.

4 The tax landscape is evolving rapidly across the Middle East. What developments in Lebanon and the wider region are having the greatest impact on businesses today, and what do you expect over the next few years?

Three things. First, the Gulf is becoming a normal tax environment: corporate tax, transfer pricing, economic substance and domestic minimum top-up taxes mean the era of structuring purely for zero tax is over, and substance now decides the outcome.

Second, Lebanon is at the start of a fiscal reconstruction. Banking sector restructuring, the restoration of state revenues and the eventual return of international financing will come with tighter enforcement and new rules, and groups that regularise their Lebanese position early will have the advantage.

Third, families are redrawing their maps. Wealth that was held through Lebanon or Europe is being redomiciled to the UAE, and that movement creates tax exposure in the country left behind as much as in the country of arrival. The opportunity over the next few years is for advisers who can hold both sides of that picture at once. The risk is for groups that treat each country as a separate file.

5 What does the future hold for Eptalex? Are there particular jurisdictions, practice areas, or strategic initiatives that you see driving the firm’s growth over the coming years?

We will keep building a firm that is regional by design rather than by referral. We are deepening the bridge between the Gulf and Europe because our clients’ capital increasingly flows in both directions.

In terms of practices, private wealth and family governance, transfer pricing and international tax, and funds and regulatory work in ADGM and DIFC are where we are investing.

We are also investing heavily in how we work: a firm-wide AI deployment across our 150 professionals, and a more institutional operating model so that a client in Beirut, Dubai or Riyadh gets the same Eptalex.

The ambition is simple. We want to be the firm that families and businesses in this part of the world call first when their question crosses a border.