Insights · Updated regularly

What the authorities are actually challenging.

Briefings drawn from the same authority-focus intelligence the platform uses — FTA and ZATCA enforcement patterns, with the practical move for each. New briefings land regularly.

Last updated — 7 August 2026

UAE · Relief

7 August 2026

Small Business Relief runs to 2029 now — but MNE members still never qualified

Ministerial Decision No. 131 of 2026 (issued 29 July 2026) extends Art. 21 relief to tax periods ending on or before 31 Dec 2029, three years past the original sunset, with the AED 3,000,000 revenue threshold unchanged. What did not move: constituent companies of multinational groups with consolidated revenue of AED 3.15B or more are excluded regardless of their own size, and a loss made in a year you elect SBR cannot be carried forward (Ministerial Decision 73 of 2023, Art. 4). Losses from earlier years wait for a year you don’t elect.

Takeaway — If you planned an exit to standard rates for FY2027, re-run it. The cliff moved; the exclusions did not.

UAE · Corporate Tax

11 June 2026

QFZP de-minimis: the 5%-or-AED 5M trap is a whole-period cliff

Breaching the lower of 5% of revenue or AED 5M doesn’t tax the excess — it disqualifies the entire entity from the 0% regime for the period and the following four. Your VAT returns and your Corporate Tax return go to the same authority, so the revenue each reports should reconcile.

Takeaway — Track non-qualifying revenue through the year, not at year-end. Model the breach before it happens.

KSA · E-Invoicing

11 June 2026

ZATCA Phase 2 is now a buyer’s problem: input VAT denied on non-cleared invoices

ZATCA’s e-invoicing guideline states that uncleared tax invoices are not eligible for VAT deduction. A supplier that fails to clear an invoice through FATOORA can therefore cost the buyer its input VAT — supplier non-compliance becomes your cost.

Takeaway — Make Phase-2 compliance a supplier-contract condition and check clearance at receipt.

KSA · Transfer Pricing

11 June 2026

KSA transfer pricing: above SAR 6M of related-party transactions, the files are mandatory

ZATCA’s Transfer Pricing Guidelines require a Master File and a Local File once the arm’s-length value of your controlled transactions exceeds SAR 6,000,000 in a 12-month period, and the files are provided on request within 30 days. For fines, the guidelines refer to the Income Tax Law.

Takeaway — Documentation is risk management even when your pricing is perfect.

MNE · Pillar Two

11 June 2026

The UAE DMTT is here — and your CbCR data quality is the safe harbour

For in-scope groups (€750M+), the Transitional CbCR Safe Harbour can deem a jurisdiction’s top-up tax to zero using CbCR data instead of a full GloBE computation — but only if your CbCR is “qualified”. Without qualified data, that jurisdiction falls back to the GloBE computation unless another safe harbour or election applies.

Takeaway — Treat CbCR as a computation input now, not a filing afterthought.

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