Hany Elnaggar examines how the region's legacy economic substance regimes and the OECD's pillar two framework are converging on the same underlying test
Hany Elnaggar examines how the OECD’s global minimum tax is reshaping the GCC’s investment incentive landscape, shifting the region from rate-based competition toward substance-driven economic positioning
Hany Elnaggar examines how the OECD’s global minimum tax is reshaping PE concepts across the GCC, shifting the focus from formal presence to substantive economic activity
Vrajesh Dutia and Ananthanarayanan R of Deloitte analyse the results of a TP controversy survey, involving TP practitioners across the globe, which seeks to gain a better understanding of the ever-evolving TP landscape.
Manisha Gupta, Iva Georgijew and Bhupendra Kothari of Deloitte discuss the transfer pricing risks that may arise due to business disruptions caused by COVID-19 with recommendations on how to manage those risks.
Ariel Krinshpun, James Mahon and Mo Malhotra of Deloitte explain why taxpayers may wish to review intra-group financing arrangements, and significant financing transactions in particular, for controversy risk.
