Expert International Tax Structuring Services in the UAE (Dubai)

Optimize your global tax footprint, ensure compliance, and leverage UAE's strategic advantages with our tailored cross-border tax solutions

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Navigating Global Tax Complexity: The UAE Advantage

Businesses operating across borders face significant challenges including double taxation, increasing compliance burdens, BEPS initiatives, and heightened transparency demands from tax authorities worldwide.

The UAE offers strategic solutions with its extensive network of Double Tax Treaties (over 100 DTTs), favorable tax regimes, clear Economic Substance Regulations (ESR) framework, and strategic geographic position between major global markets.

At Inlex Partners, we leverage the UAE's advantages to design compliant, efficient international tax structures that align with your business objectives while navigating the complex global regulatory landscape.

Defining International Tax Structuring for Global Businesses

International Tax Structuring involves designing tax-efficient legal and operational frameworks for businesses with cross-border activities. It ensures compliance with multiple tax jurisdictions while optimizing the overall tax position.

Key International Tax Structuring Principles

  • Tax Efficiency: Minimizing unnecessary tax leakage while maintaining full compliance with relevant tax laws
  • Commercial Substance: Ensuring structures reflect genuine business purpose and economic reality, not just tax advantages
  • Risk Management: Identifying and mitigating potential tax risks across various jurisdictions through proper planning
  • Sustainable Design: Creating structures that remain effective despite evolving tax rules and regulatory developments

Effective international tax structuring in the UAE context means leveraging the emirate's strategic position, extensive treaty network, and favorable tax regime while ensuring compliance with global standards including BEPS, Pillar Two requirements, and Economic Substance Regulations.

Comprehensive International Tax Structuring Solutions in the UAE

Tailored cross-border tax solutions leveraging UAE's strategic advantages and extensive treaty network

Holding Company Structures

Designing and implementing tax-efficient holding structures in UAE (Mainland/Free Zones) to optimize global tax exposure and enhance asset protection.

Regional Headquarters Setup

Advisory on establishing RHQs in Dubai/UAE for optimal tax and operational benefits, leveraging the strategic location between East and West.

Double Tax Treaty Planning

Utilizing the UAE's extensive DTT network to minimize withholding taxes, prevent double taxation, and create efficient cross-border structures.

BEPS & Pillar Two Advisory

Guidance on compliance with OECD's Base Erosion and Profit Shifting actions and Pillar Two global minimum tax rules impacting UAE structures.

UAE Economic Substance Regulations

Ensuring structures meet necessary substance requirements while maintaining tax efficiency in line with UAE regulatory frameworks.

Financing & Treasury Structures

Optimizing cross-border financing, cash pooling, and treasury functions to enhance liquidity and reduce global tax leakage.

M&A Tax Structuring

Tax due diligence and structuring for cross-border deals involving UAE entities to minimize transaction taxes and future tax exposure.

Supply Chain Optimisation

Designing tax-efficient supply chain structures that align with operational needs while leveraging UAE's strategic advantages.

Who Needs International Tax Structuring in the UAE?

Our solutions are tailored for diverse businesses with cross-border operations

Multinational Enterprises

Global companies seeking to optimize their international tax footprint while maintaining compliance with multiple jurisdictions

Family Offices & HNWI

High-net-worth individuals and family offices looking to protect and efficiently structure international assets and investments

International Investors

Entities making cross-border investments who need efficient holding structures to minimize withholding taxes and maximize returns

Expanding Businesses

Companies expanding internationally who need to establish tax-efficient operational structures from the outset

Our International Tax Structuring Process

A systematic approach to designing and implementing tax-efficient cross-border structures

1. Initial Assessment

Comprehensive evaluation of your current structure, cross-border operations, and identification of tax inefficiencies and compliance gaps.

2. Strategic Planning

Development of customized tax structuring solutions that align with your business objectives and address identified inefficiencies.

3. Documentation

Preparation of comprehensive documentation supporting the structure's commercial rationale and tax positions across jurisdictions.

4. Implementation

Coordinated execution of the proposed structure, including entity formation, registration, and operational setup across relevant jurisdictions.

5. Compliance Management

Ongoing support for maintaining regulatory compliance, including Economic Substance requirements and tax filing obligations.

6. Regular Reviews

Periodic assessment and optimization of your international tax structure to adapt to changing business needs and evolving regulatory landscapes.

Common Questions About International Tax Structuring in the UAE

Expert answers to help you understand how UAE tax structures can benefit your global business

What are the tax benefits of establishing a holding company in the UAE?
UAE holding companies offer numerous tax advantages including: no withholding taxes on dividends, interest or royalties; an extensive double tax treaty network (100+ DTTs); no capital gains tax; and various free zone incentives. Under the UAE Corporate Tax regime, holding companies can also benefit from participation exemptions on qualifying dividends and capital gains from domestic and foreign subsidiaries, making the UAE an attractive jurisdiction for international holding structures.
How do the UAE's Economic Substance Regulations affect international tax structures?
UAE Economic Substance Regulations (ESR) require entities engaged in relevant activities to demonstrate adequate economic substance in the UAE. This means having appropriate levels of qualified employees, physical presence, core income-generating activities, and expenditure in the UAE. International tax structures must be designed to meet these substance requirements while maintaining tax efficiency. Our approach ensures structures are not only tax-optimized but also fully compliant with ESR, with substance aligned to the value creation within your business operations.
How will the global minimum tax (Pillar Two) impact UAE-based structures?
The OECD's Pillar Two global minimum tax (15%) affects multinational enterprise groups with consolidated revenues exceeding €750 million. UAE-based structures within these groups may be subject to top-up taxes if their effective tax rate falls below 15%. Despite this, the UAE remains advantageous for international structuring due to its strategic location, infrastructure, treaty network, and business-friendly environment. Our international tax specialists help redesign structures to maintain efficiency while ensuring compliance with Pillar Two requirements through careful income allocation and substance planning.
Can UAE free zones still be used effectively in international tax structures?
Yes, UAE free zones remain valuable components in international tax structures, even with recent regulatory changes. Free zones offer advantages including 0% corporate tax rates for qualifying activities under free zone tax holidays, streamlined setup processes, 100% foreign ownership, and specialized industry clusters. While free zone entities must now comply with Economic Substance Regulations and may be impacted by the UAE Corporate Tax regime for non-qualifying income, they continue to provide significant benefits when properly structured within a global tax framework. Our team specializes in optimizing free zone structures within comprehensive international tax planning.
What documentation is required to support international tax structures using UAE entities?
Robust documentation is crucial for international structures using UAE entities. This typically includes: transfer pricing documentation for related-party transactions; economic substance reporting for relevant activities; corporate tax returns and supporting analysis; commercial rationale and business purpose documentation; legal agreements substantiating the structure; and board meeting minutes demonstrating strategic decision-making in the UAE. Our comprehensive approach ensures all documentation is aligned with both UAE requirements and international standards, providing defensibility against potential challenges from tax authorities worldwide.

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