Insights · Updated weekly

What the authorities are actually challenging.

Briefings drawn from the same authority-focus intelligence the platform uses — FTA and ZATCA enforcement patterns, with the practical move for each. New briefings land every week.

Last updated — 11 June 2026

MNE · Pillar Two

11 June 2026

DMTT is here — and your CbCR data quality is the safe harbour

For in-scope groups (€750M+), the transitional CbCR safe harbour is the cheapest path through the first years of Pillar Two — but it only works if your CbCR is “qualified”. Disqualified data means full GloBE computations, entity by entity.

Takeaway — Treat CbCR as a computation input now, not a filing afterthought.

KSA · Transfer Pricing

11 June 2026

The SAR 6M TP documentation threshold carries a 2%-of-gross penalty

Above SAR 6M of related-party transactions, Local and Master File documentation is mandatory — and the documentation penalty is charged on the gross transaction value, not the tax adjustment. SAR 50M of intercompany flows = SAR 1M exposure before any pricing argument begins.

Takeaway — Documentation is risk management even when your pricing is perfect.

KSA · E-Invoicing

11 June 2026

ZATCA Phase 2 is now a buyer’s problem: input VAT denied on non-cleared invoices

ZATCA has been systematically denying input-VAT recovery where supplier invoices were not cleared through FATOORA. Buyers are expected to validate UUID and cryptographic stamp at receipt — supplier non-compliance becomes your cost.

Takeaway — Make Phase-2 compliance a supplier-contract condition and validate at receipt.

UAE · Relief

11 June 2026

Small Business Relief sunsets 31 December 2026 — and MNE members never qualified

Art. 21 relief is only available for tax periods ending on or before 31 Dec 2026, and members of groups with consolidated revenue ≥ AED 3.15B are excluded regardless of their own size. Electing SBR also permanently forfeits prior losses.

Takeaway — If your FY ends after the sunset, plan for standard rates now.

UAE · Corporate Tax

11 June 2026

QFZP de-minimis: the 5%-or-AED 5M trap is a whole-period cliff

Breaching the lower of 5% of revenue or AED 5M doesn’t tax the excess — it disqualifies the entire entity from the 0% regime for the period and the following four. FTA is cross-referencing EmaraTax VAT data against CT returns to find breaches.

Takeaway — Quantify mainland revenue continuously, not at year-end. Model the breach before it happens.