UAE Holding Structure of GCC operations – Financial Services ​

• Advised on the optimal structure for holding and financing the entities interests and operations of the Group in a tax efficient manner, including direct and withholding tax implications of the Group operating structure. In this respect advised on the tax advantages of using ADGM as a holding, financing and headquarter jurisdiction for Group;​
• We advised on the tax implications of repatriating income from the operating companies up to the ultimate shareholders in the UAE; ​
• We advised on the conditions and procedure to obtain a tax residence certificate for the UAE entities to avail double tax treaties benefits in the operating countries; ​
• We will also advise on the capital gains tax implications realized upon exit at the level of the ADGM HoldCo and its subsidiaries under applicable tax treaties. ​
• We provided practical recommendation on how to manage the companies part of the Group order to avoid tax residency risks in foreign jurisdictions and challenge of the application of double tax treaties provisions by foreign tax authorities. ​