International Tax Strategy & Cross-Border Structuring

Introduction As the global economy becomes increasingly digital, governments worldwide are seeking new ways to tax large technology companies operating across borders. Traditional tax systems rely heavily on physical presence, which has proven ineffective for digital platforms, streaming services, online marketplaces, and advertising networks that generate substantial revenue without being physically present in a country. […]

Introduction In recent years, “Beneficial Ownership (BO)” has become one of the most critical compliance topics for governments, tax authorities, and financial regulators across the Middle East and North Africa. As global transparency standards increase driven by OECD, FATF, CRS, and international anti–money laundering frameworks  countries in the region have strengthened their requirements for identifying

Introduction The GCC region particularly Saudi Arabia, the United Arab Emirates, and Qatar has become one of the world’s most attractive destinations for business expansion. With strong economic growth, strategic geographic positioning, and ambitious national development plans, these markets offer enormous opportunities for multinational companies. However, the GCC also has complex and rapidly evolving tax

Introduction The Middle East and North Africa (MENA) region has become an increasingly attractive location for establishing holding company structures. Multinationals and regional groups alike use holding companies to centralize ownership, streamline cross-border operations, optimize taxes, and enhance asset protection. However, despite the advantages, holding structures in MENA come with regulatory, tax, and operational challenges.

Introduction A Tax Residency Certificate (TRC) is one of the most important documents for businesses and individuals seeking to benefit from Egypt’s network of Double Tax Treaties (DTTs). It allows the taxpayer to prove residency in Egypt and legally claim reduced withholding tax, avoid double taxation, and secure better outcomes for cross-border transactions. Applying for

Introduction Intercompany loans are an essential financing tool for multinational groups. They allow businesses to optimize internal cash flows, fund subsidiaries, support expansion, and manage liquidity efficiently. However, these loans come with significant tax implications, especially under the OECD Transfer Pricing Guidelines and the BEPS framework. Improperly structured loans, excessive interest rates, or insufficient documentation

Introduction As companies expand across borders, service agreements between related or unrelated entities become a central part of multinational operations. However, poorly drafted cross-border service agreements often create unnecessary double taxation, disputes with tax authorities, and inefficient tax outcomes. To avoid these issues, businesses must develop clear, compliant, and strategically structured agreements that align with

Introduction As companies expand internationally, the concept of a Permanent Establishment (PE) becomes one of the most critical and complex pillars of global tax strategy. PE exposure determines whether a foreign business becomes taxable in another jurisdiction, and mismanaging this exposure can create significant financial, legal, and operational risks. Understanding how PE rules work, when

Introduction As Egyptian and Middle Eastern multinationals continue to expand across borders, international tax compliance has become increasingly complex and high-risk. Global regulatory frameworks are evolving rapidly, driven by BEPS 2.0, the Global Minimum Tax, strengthened transfer pricing rules, and heightened enforcement by tax authorities worldwide. For companies operating across MENA, Europe, Africa, and beyond,

Introduction As multinational enterprises expand across the Middle East, tax structuring becomes a critical strategic priority. The region is experiencing rapid economic transformation, the introduction of new corporate tax regimes, strengthened transfer pricing rules, and increasing alignment with global standards such as BEPS 2.0 and the Global Minimum Tax.For global groups, the Middle East offers