Our Core Services

Cross-Border Tax Advisory & Global Compliance Solutions

Pillar Two and Global Minimum Tax Advisory

The UAE has implemented a Domestic Minimum Top-up Tax of 15% for large multinational groups. It applies to groups with consolidated revenue of EUR 750 million or more, for financial years starting on or after 1 January 2025. We assess your exposure, safe-harbour eligibility and reporting obligations under the UAE's framework.

FinApt experience:

Pillar Two safe-harbour advisory delivered for a group in the investment and holding sector.

Cross-Border Tax Advisory

Advisory on the tax implications of operating, investing or transacting across more than one jurisdiction. This covers structuring, withholding tax exposure, and coordination between UAE and foreign tax positions.

Double Tax Treaty Advisory

The UAE has an extensive double tax treaty network. We help you determine whether treaty relief applies to your structure and how to claim it. That reduces the risk of being taxed twice on the same income.

Permanent Establishment Advisory

Operating in a foreign market can create a taxable presence you did not intend. The same applies to foreign entities operating in the UAE. We assess permanent establishment risk before it becomes an exposure, and advise on structuring to manage it.

International Structuring

Advice on how to structure holding, financing and operating entities across jurisdictions. Tax-efficient and compliant with UAE and international substance requirements.

International Tax Reporting and Compliance

Ongoing support for the reporting obligations that come with cross-border structures. This includes coordination with Country-by-Country Reporting alongside your transfer pricing documentation.

Why FinApt Group

Why FinApt Group for International Tax

International tax advisory delivered alongside transfer pricing and corporate tax. Cross-border structuring accounts for all three from the outset.

Experience with UAE, GCC and international holding structures

Senior partners engaged directly on complex, cross-border mandates

Common Inquiries

Frequently Asked Questions

Pillar Two generally applies to large multinational groups with consolidated revenue of EUR 750 million or more. Most UAE businesses fall outside scope. Groups approaching that threshold should get an assessment done in advance.

A permanent establishment is a level of taxable presence a business can create in a country through its activities there, even without a registered entity. It triggers tax obligations in that country. Structuring and monitoring activity levels helps manage this risk.

Where the UAE has a treaty with the country you are transacting with, treaty relief can reduce or eliminate double taxation on the same income. Relief has to be claimed correctly and supported with the right documentation.

The two are closely linked. Cross-border structuring decisions directly affect your transfer pricing position. CbCR reporting under transfer pricing rules feeds into your international tax compliance. See our transfer pricing services.

Global Tax Advisory

Optimize Your Cross-Border Tax Strategy

Navigate Pillar Two regulations, manage permanent establishment risk, and maximize double tax treaty relief with FinApt Group.