Compliance



BEPS 2.
BEPS 2.0 has two parts or pillars, namely, Pillar One and Pillar Two. Pillar One is focused on the reallocation of (a portion of) the consolidated profit of a multinational enterprise to jurisdictions where sales arise as well as the standardisation of the remuneration of routine marketing and distribution activities. Pillar Two, on the other hand, introduces a global minimum effective tax rate of 15 %.
The BEPS 2.0 proposals will impact every MNE in the Middle East that has consolidated turnover in excess of 750M Euros and undertakes intra-group transactions.
While the impact of the Pillar 1 proposals cannot be ignored, we expect the Pillar 2 proposals, or the introduction of a global minimum tax, to have the biggest impact on Middle East groups given the hybrid model of corporate tax and Zakat in KSA and Kuwait, and the no- or low-tax environment in the UAE and Bahrain.
Therefore, it is important to assess the impact and involve stakeholders as soon as practically possible to avoid any unexpected surprises from both a financial and compliance perspective.
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