KPMG Lower Gulf’s Post

📢 Transfer Pricing Alert 📢 On 20 & 24 May 2024 the Cyprus Tax authorities issued further guidance with respect to the preparation and submission of the Summary Information Table (SIT) and the Quality Assurance Review. Check out our latest Transfer Pricing Alert for the key points included in the relevant guidance.

📢 Transfer Pricing Alert 📢 On 20 & 24 May 2024 the Cyprus Tax authorities issued further guidance with respect to the preparation and submission of the Summary Information Table (SIT) and the Quality Assurance Review. Check out our latest Transfer Pricing Alert for the key points included in the relevant guidance.

On April 22, FIAA reacted on the notification of the Ministry of Finance on the draft instruction “On Implementing the Agreements on Avoiding Double Taxation and Preventing Fiscal Evasion” by collecting and sharing the suggestions of its members, elaborated in detail by its Tax Committee. The list of topics addressed in FIAA’s document includes the excess in the purpose of the instruction, the application deadlines, the reference to the Multilateral Instrument and the commentaries, the lack of clarifications in certain cases, lack of clarity in terminology, contract between parties, other requests for documentation, the certificate of residence, the opportunity for consultation of the tax payers, the exchange of information, and the lack of transitory dispositions. FIAA thanks all members involved in this process, especially the experts active in its Tax Committee for their professional advice and commitment under the leadership of Mrs. Alba Paparisto. #FIAA #Albania #FIAATaxCommittee #ReactionDraftInstruction #AvoidingDoubleTaxation #PreventingFiscalEvasion

𝐊𝐮𝐰𝐚𝐢𝐭’𝐬 𝐓𝐚𝐱 𝐋𝐚𝐧𝐝𝐬𝐜𝐚𝐩𝐞 𝐢𝐬 𝐄𝐯𝐨𝐥𝐯𝐢𝐧𝐠: 𝐀𝐫𝐞 𝐘𝐨𝐮 𝐑𝐞𝐚𝐝𝐲? Kuwait’s draft law on Business Profits Tax (BPT) and Domestic Minimum Top-Up Tax (DMTT) marks a transformative step toward aligning with global tax standards under the OECD's Pillar Two framework. 💡 𝐊𝐞𝐲 𝐇𝐢𝐠𝐡𝐥𝐢𝐠𝐡𝐭𝐬: ✅ 15% Business Profits Tax: Applies to MNEs with phased implementation starting January 2025 for revenue above EUR 750M, expanding to businesses with KWD 1.5M+ from 2027. ✅ DMTT: Ensures an effective tax rate of 15% for MNEs operating in Kuwait, safeguarding the local tax base. ✅ 5% Withholding Tax: Applicable to non-resident payments for dividends, royalties, and technical services. 📌 Why This Matters: This new framework modernizes Kuwait’s tax regime, aligning it with international norms to prevent base erosion and foster fairness while maintaining a stable and transparent business environment. AJMS Global is here to help you stay ahead of the curve. Learn more about the potential impact on your operations by reaching out today! Dr. Abhishek Jajoo Raed AlMoumen,MBA,FCCA,CPA,ICVS Vivek Mundhra Udit Wadhwa Ajit Jain CA Darshika Agrawal #TaxReform #KuwaitTax #BusinessProfitsTax #OECDPillarTwo #DMTT #TaxCompliance

On September 1, 2024, Bahrain announced a 15% Domestic Minimum Top-up Tax (DMTT) for large multinational enterprises, effective January 2025. This aligns with the OECD’s global minimum tax framework. Our latest analysis by A&M tax experts explores the implications of this new law, including its potential impact on Bahrain’s economy, GCC alignment, and compliance requirements for businesses. We also discuss how this policy might influence tax strategies across the Middle East and reshape investment decisions for international groups. ➡ Read the full insight to understand how this may affect your organisation: https://okt.to/GNp8CH Vishal Sharma Jordan Gill (ATT, CTA) Matilde Barroso

The implications of #Bahrain's #DMTT by Vishal Sharma, Jordan Gill (ATT, CTA) & Matilde Barroso. #Kuwait is also in a similar position. There is no generic corporate tax, only a 15% tax on foreign companies. So, a similar question applies to Kuwait as well: once it announces a DMTT (if one is announced), will it go on to introduce a generic corporate tax or not? 😊

Check out our recent discussion with Helal Alrefai, Senior Proposition Manager at Thomson Reuters, where we explore the potential introduction of VAT in Qatar. With no existing indirect tax system in place, businesses and taxpayers could face significant challenges if VAT is implemented. This video provides valuable insights into proactive strategies that can help you prepare, including engaging with stakeholders, consulting with tax experts, evaluating current systems for VAT compliance, and leveraging advanced tax technology solutions. Notably, around 85% of the necessary groundwork can be completed even before any final legislation is announced. Click here to find out more: https://lnkd.in/d8aTvbFv #ThomsonReuters #VAT #Qatar #TaxCompliance #TaxTechnology #ProactivePlanning #Innovation

Bahrain is poised to implement a Domestic Minimum Top-up Tax (DMTT) starting January 1, 2025, which will apply to multinational companies with global revenues exceeding €750 million. This tax ensures a minimum 15% tax rate on profits within Bahrain, aligning the nation with the OECD's global tax framework to curb profit shifting and tax avoidance. This development represents a shift in Bahrain’s traditionally low-tax environment, potentially affecting its status as a competitive business hub within the GCC. While it reflects Bahrain’s commitment to global tax standards, it may prompt multinational enterprises to reassess their regional strategies. The introduction of the DMTT also underscores Bahrain’s broader economic diversification efforts, reducing reliance on oil revenues and reinforcing its position as a transparent jurisdiction. As the global tax environment continues to evolve, businesses operating in Bahrain will need to carefully evaluate the impact of this new regime on their operations and financial planning. The DMTT is not just a local policy change but a reflection of the broader global trend towards ensuring fairer tax practices across borders, marking a new era in Bahrain's economic landscape. #Bahrain #economy #gcc #tax #business #middleeast via Ministry of Finance and National Economy

The master file should provide an overview of the Global Associated Enterprises (GAEs) group business, including information on the nature of its global business operations, its transfer pricing policies, and its global allocation of income and economic activity. This information is meant to provide a high-level overview to give the relevant global economic, legal, and financial context on transfer pricing practices. Such information should be included in a master file if its exclusion would impact the reliability of the transfer pricing outcomes. The Master File is required to be submitted to the Egyptian Tax Authority (“ETA”) by the due date of filing the parent entity’s tax return.

Virusha Subban and Denny Da Silva Chartered Tax Adviser (CTA) explore the transfer pricing landscape, particularly in the context of transactions and related obligations in South Africa, for Chambers and Partners Expert Focus: https://lnkd.in/emmdq2ye #transferpricing