As global tax rules continue to evolve at unprecedented speed, BEPS (Base Erosion and Profit Shifting) has become one of the most critical regulatory frameworks impacting multinational enterprises. Fathalla FBC stands at the forefront of this transformation, providing world-class BEPS consulting to help international and regional groups navigate the complexities of OECD regulations with clarity, control, and strategic confidence.
A Trusted Partner in BEPS Compliance
Fathalla FBC supports multinational companies in understanding the full scope of BEPS requirements, including Pillar One, Pillar Two, transfer pricing alignment, and transparency reporting obligations.
The firm’s approach ensures accurate, compliant, and audit-ready documentation while maintaining operational efficiency across multiple jurisdictions.
Core BEPS consulting capabilities include:
✔ Pillar Two – Global Minimum Tax Advisory
Fathalla FBC provides a strategic framework for companies affected by the 15% Global Minimum Tax, offering:
ETR (Effective Tax Rate) calculations
GloBE, IIR, and QDMTT impact analysis
Transitional Safe Harbor assessments
Scenario modeling and future-proof tax planning
Preparation for jurisdiction-level reporting
This helps multinational groups stay compliant while optimizing tax positioning across all impacted entities.
✔ BEPS Action Plan Implementation
Fathalla FBC offers full guidance across all BEPS actions, with a focus on:
Aligning tax structures with economic substance
Ensuring accurate transfer pricing policies
Strengthening transparency and anti-avoidance measures
Supporting robust internal governance
Reducing exposure to tax disputes and penalties
The firm ensures that group structures meet OECD expectations and local regulatory requirements.
✔ CbCR, Master File & Local File Reporting
To support BEPS Action 13 on transparency:
Country-by-Country Reporting (CbCR) preparation
Master File documentation reflecting global operations
Local File documentation aligned with local jurisdiction rules
Consistency checks across intercompany flows and value-chain mapping
Audit defense support in case of tax authority review
Clients benefit from clear, comprehensive reporting that withstands regulatory scrutiny.
✔ Transfer Pricing Alignment
Since Transfer Pricing is central to BEPS compliance, Fathalla FBC ensures:
Accurate benchmarking studies
TNMM, CUP, CPM analysis
Intercompany pricing reviews
Value creation mapping
Substance and risk alignment
This guarantees that intercompany arrangements reflect the true economic reality required under BEPS guidelines.
Why Multinationals Choose Fathalla FBC for BEPS Consulting?
1. Deep Global Expertise
Experience across Europe, GCC, North Africa, and emerging markets.
2. Advanced Technical Knowledge
Extensive command of OECD rules, BEPS actions, and Pillar One/Pillar Two frameworks.
3. Strategic Approach
The firm goes beyond compliance to build tax-efficient, future-proof structures.
4. Proven Documentation Quality
Reports are crafted to withstand tax audits and authority challenges.
5. Multijurisdictional Insight
Understanding of how BEPS impacts businesses operating across the MENA region.
A BEPS Partner for the Future of Global Taxation
With worldwide adoption of BEPS and the enforcement of Global Minimum Tax, multinational companies need a partner who understands both compliance and strategy. Fathalla FBC delivers the expertise and guidance required to help organizations adapt, protect value, and remain ahead of global tax changes.
Fathalla FBC is committed to offering a clear roadmap for BEPS compliance, ensuring that multinational groups operate with transparency, fairness, and resilience in an evolving global tax landscape.

