Where the Vanguards of Tax harness galactic fiscal wisdom!
For multinational groups, CFOs & tax advisory firms
The Council
Where the Vanguards convene on cross-border UAE tax — global minimum tax, R&D credits, and entity structuring, ruled on in one suite.
Three seats at the table for the questions that cross a border: where the structure should sit, what the incentives are worth, and what the global minimum tax will cost. Every verdict is traced to the primary legislative text, not to secondary commentary.
Pillar Two Tool
A single working model for intercompany flows, transfer pricing, withholding tax and Pillar Two Top-up Tax: GloBE Income under Article 3.2, covered tax adjustments under Article 4.1, the Substance-Based Income Exclusion, de minimis, Top-up Tax and the UTPR allocation key — plus a GIR draft mapped to the OECD's July 2023 template. Covers nineteen G20 members, the six GCC states and the leading offshore centres, with editable rates.
R&D Tax Credit Tool
A decision-support system for the UAE R&D Tax Credit (Cabinet Decision No. 215 of 2025 and Ministerial Decision No. 24 of 2026): eligibility screen, qualifying expenditure with the 30% overhead uplift, the tiered 15%/35%/50% rates and their minimum R&D headcount conditions, the non-refundable AED 2,000,000 annual cap — and a build-vs-buy and M&A price floor/ceiling model for acquiring a target that carries R&D assets.
UAE Entity Structuring Navigator
A deterministic Free Zone vs. Mainland entity and vehicle selector verified against Federal Decree-Law No. 47 of 2022, the VAT Law and their Cabinet and Ministerial Decisions: Qualifying vs. Excluded Activity screen, the de minimis ceiling, Domestic PE flag, adequate substance test, Small Business Relief sunset, the Tax Grouping incompatibility, branch vs. subsidiary guidance and the parallel VAT position.
Access
Pricing available on request
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Not tax or legal advice. Planning aids for directional analysis only — every structure still requires a genuine functional and risk analysis and review by qualified counsel in each jurisdiction involved.