This session explores the tax implications of using UAE holding companies and financing structures, drawing on the UAE Corporate Tax framework, participation exemption rules, and international tax considerations. As businesses increasingly look to the UAE as a regional hub for holding and treasury activities, understanding the tax treatment of these structures — including interest deduction limitations, QFZP eligibility, and transfer pricing requirements — is essential for CFOs, tax directors, and their advisers.
KEY AREAS COVERED
● Holding company structures in the UAE: locations (mainland vs. free zone), key features, and licensing implications
● Corporate Tax frameworks: 0% and 9% rates, participation exemptions, and free zone benefits for QFZPs
● Interest deduction limitations: General and Specific Interest Deduction Limitation Rules (GIDLR and SIDLR)
● International tax context: foreign tax credits, tax treaty access, and permanent establishment risk
● Transfer pricing requirements for intra-group financing and management services
● VAT treatment of holding company and financing activities: input VAT recovery and deductibility
● Practical structuring considerations and risk areas identified in recent FTA audit activity
LEARNING OUTCOMES
Participants will gain a structured understanding of how to set up and manage UAE holding and financing structures in a tax-efficient and compliant manner, including the key pitfalls to avoid.
SPEAKER
Thomas Vanhee | Founding Partner, Aurifer
Thomas Vanhee is the Founding Partner and Managing Director of Aurifer. He advises on UAE and GCC tax matters including Corporate Tax, VAT, Transfer Pricing, Pillar Two/GloBE, and international structuring across all six GCC states. Thomas leads the firm's practice and has extensive experience advising investment funds, private equity sponsors, and asset managers on all aspects of UAE and regional taxation.
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