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May 15, 2026

CHAPTER 6 - CORPORATE RESTRUCTURINGS AND HOLDING STRUCTURES

Article 51 - CEs Joining or Leaving the MNE Group

The following provisions apply when an Entity (the “Target Entity) becomes or ceases to be a CE of an MNE Group as a result of a transfer of direct or indirect Ownership Interests during a Tax Period (referred to as the “Acquisition Year):