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
Eddie Morris, Jennifer Breeze and Janelle Sadri discuss how the growth in the number of mutual agreement procedures, coupled with fine-tuning of the process, has affected its themes of access, resolution and implementation.
Ramón López de Haro and Alejandro Paredes evaluate how promoting the negotiation of advance pricing agreements (APAs) may raise the confidence of potential investors in the region.
Aaron Wang, Vrajesh Dutia and Chris In explain how adopting global best practices has proved to be beneficial for the development of dispute resolution procedures in China, India and South Korea.