Service · Advisory

Tax & substance structuring

Structure your Gulf group before you file, not after — so your effective tax position, economic substance and banking all hold together. Honest modelling across corporate tax, DMTT, VAT and Zakat, with no "zero tax" shortcuts.

At a glance

Focusstructure & substance
CoversCIT · DMTT · VAT · Zakat
Outputmodelled position
JurisdictionsBH · SA · AE
What's included

Get the structure right first

01

Effective-rate modelling

Your real blended position across corporate tax, DMTT, VAT and Zakat — before you commit.

02

Substance that stands up

Structures with genuine substance that satisfy ESR, banks and MISA scrutiny.

03

Group & holding design

Where to hold IP, cash and contracts across the Gulf without tripping anti-avoidance rules.

04

Pillar Two / DMTT readiness

For groups near the EUR 750m threshold, a clear top-up-tax view and action plan.

We provide corporate-services advisory and modelling. Where a matter needs a formal legal or tax opinion, we bring in regulated local counsel — so you always know who is accountable for what.

How we work

Modelled, documented, implemented

Advice you can act on — a modelled position and a documented structure, then implemented with your formation rather than left as a slide deck.

Position review & modellingUpfrontone-off
Structure recommendationDocumentedone-off
Implementation with formationCoordinatedwith setup
Annual substance reviewKeeps ESR intacton request
Good to know

Tax & substance FAQ

Does the Gulf really have zero tax?
No. Bahrain has no general corporate income tax but a 15% DMTT on large groups; Saudi Arabia has 20% CIT plus Zakat; the UAE has 9% corporate tax. We model your actual position rather than sell a headline.
What is the DMTT?
Bahrain's 15% Domestic Minimum Top-up Tax on multinational groups above EUR 750m in global revenue, under the OECD Pillar Two framework. See the DMTT explained.
Why does substance matter?
Because banks, ESR rules and MISA all test whether a structure is real. Thin substance risks account refusal, ESR penalties and tax challenge — we build structures that hold up.
Can you structure a multi-country Gulf group?
Yes. We design where to place holding, IP, cash and contracts across Bahrain, Saudi Arabia and the UAE so tax and substance align.

Structure it before you file.

Get a modelled, honest view of your Gulf tax and substance position — and a structure that banks, ESR and MISA will accept.

Speak to an Advisor