International tax treaty Selected Credentials
International tax treaty aspects are hugely complex. Our team has worked on major treaty aspects such as:
Indian Ministry of Finance denied double tax treaty relief to our client on the basis that it had not sought designation status to the competent authority to avail the Indian/UAE Air Transport Tax Treaty position. We initiated the Mutual Agreement Procedure working closely with the UAE Ministry of Finance.
Directly engaged with the Indian Ministry of Finance at the Joint Secretary level and the UAE’s Ambassador to India. Our team was the lead negotiator which also drafted technical positions supporting the designation and compared similar positions in other double tax treaties that India had entered into.
Obtained exemption for our UAE client despite the absence of Double Tax Agreement between the UAE and Cyprus, Maldives and Brazil through alternative exemptions.
Provided technical expertise and support to the various Ministry of Finance and Fiscal Authorities across the following areas:
UK/UAE Double Tax Agreement
Part of the technical review process of the UK/UAE DTA, recommending changes and adoptions to various treaty provisions.
UAE’s (bilateral Investment Treaty) BIT network
Integral member of the UAE MoF’s working group to re-evaluate UAE’s BIT’s from a policy, consistency, tax and legal perspective. Provided expert tax advise and assistance; align with DTA network. Recommended enhanced BIT provisions and aligned to the network to facilitate and enhance government’s investment strategy objectives.
UAE’s CBCR and BEPS steering committee
Member of the Steering Group on UAE’s CBCR and BEPS initiatives. Advised on the key implications for legislation adaptation. Advised on whether the adoption of CBCR and BEPS should use OCED standard provisions and legislative framework.
Part of UAE MoF overseas delegations to discuss and advocate tax matters with counterparts. Ensured stakeholders were briefed on key issues and implications. Enhanced value in the negotiations with the counterpart to ensure UAE interest are promoted and protected.
Drafted a new Air Transportation Tax Convention on behalf of the Council of Arab Transport Ministers.
Worked with Arab Air Carrier Organisation (AACO) and the Arab Civil Aviation Organization (ACAO) under the umbrella of the League of Arab States to completely revise the old Tunis Convention 1979 on the ‘Reciprocal Exemption from Taxes and Charges of Arab Air Transport Enterprises’ and bring it into line with international standards and best practice. Completed a new draft replacing the older Tunis Convention.
The Council of the League of Arab States approved the new version of the Convention.
Others
Abu Dhabi Global Markets (ADGM), UAE wanted to establish itself as new and leading efficient and robust aircraft leasing jurisdiction. Assisted with the drafting of an MoU with the UAE MOF and Tax Residency Certificate (TRC) requirements for entities registered in the ADGM.
Member of the IATA Tax Working Group for a period of three years. Supported it with identifying and addressing major international tax matters affecting the airline industry.
This involved drafting policy positions, considering the practical implications of implementing article 8 provisions of the DTA and reciprocal exemptions etc. Involved in advocacy matters with the relevant taxing authority.