Blog - Fathalla FBC

TP in the Manufacturing Sector: Common Challenges and Solutions

Introduction Transfer Pricing (TP) in the manufacturing sector is uniquely complex. Manufacturers operate across multiple jurisdictions, manage global supply chains, engage in intercompany procurement, employ valuable intangibles, and often follow integrated production models. Because of this, transfer pricing is one of the most scrutinized areas during tax audits especially for companies with contract manufacturing, toll […]

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How to Handle Year-End TP Adjustments: Practical Steps for Compliance

Transfer Pricing (TP) Deep Dives

Introduction Year-end transfer pricing (TP) adjustments are a critical compliance tool used by multinational enterprises (MNEs) to ensure their intercompany transactions align with the arm’s-length principle. Since actual financial performance often differs from projected margins, groups must assess and correct their transfer pricing results before closing the fiscal year. When performed correctly, year-end TP adjustments

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Management Fees and Head Office Charges: How to Document and Defend Them

Transfer Pricing (TP) Deep Dives

Introduction Management fees and head office charges are some of the most common and most controversial intercompany transactions in multinational groups. Tax authorities across the world challenge these payments because they can be used (or perceived as being used) to shift profits between jurisdictions. To avoid disputes, adjustments, or penalties, multinational enterprises must justify, document,

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Intangibles and Royalty Transactions – How to Benchmark and Justify the Arm’s Length Price

Transfer Pricing (TP) Deep Dives

Introduction Intangible assets such as trademarks, patents, software, technology, and know-how have become the most valuable drivers of profitability in multinational enterprises (MNEs). As a result, royalty transactions involving these intangibles are among the most heavily scrutinized areas in transfer pricing. Because intangibles are unique, difficult to value, and often transferred within related parties, tax

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The Importance of Functional and Risk Analysis (FAR) in Transfer Pricing Documentation

Transfer Pricing (TP) Deep Dives

Introduction Transfer pricing rules around the world are built on a single foundation: the arm’s-length principle. To determine whether related-party transactions comply with this principle, tax authorities rely heavily on Functional and Risk Analysis (FAR). A robust FAR analysis is the backbone of defensible TP documentation without it, even the most sophisticated benchmarking or economic

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Selecting the Right Transfer Pricing Method: TNMM vs CUP vs Cost-Plus Explained

Transfer Pricing (TP) Deep Dives

Introduction Transfer pricing is one of the most scrutinized areas in international taxation. As multinational companies increasingly engage in cross-border transactions such as services, goods, financing, and IP transfers tax authorities expect these transactions to follow the arm’s-length principle. Choosing the right transfer pricing method is critical for ensuring compliance, avoiding disputes, and reducing tax

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Digital Services Tax (DST) and Its Impact on Cross-Border Technology Companies

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.

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Understanding Beneficial Ownership Rules in Egypt and Across the Region

International Tax Strategy & Cross-Border Structuring

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

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Tax Considerations When Expanding to the GCC (Saudi Arabia, UAE, Qatar)

International Tax Strategy & Cross-Border Structuring

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

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Holding Company Structures in the MENA Region: Opportunities and Pitfalls

International Tax Strategy & Cross-Border Structuring

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.

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Practical Steps for Tax Residency Certificate Applications in Egypt

International Tax Strategy & Cross-Border Structuring

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

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Tax Implications of Intercompany Loans and Interest Payments under OECD Guidelines

International Tax Strategy & Cross-Border Structuring

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

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