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May 15, 2026

SECTION 8 - TAX AVOIDANCE

Chapter 2 - Indirect Transfer of Profits between Related Entities

Article 54

Every entity linked to others must perform and report a functional analysis in its tax returns, considering the comparable data available.

The functional analysis should describe the entity's economic position and role relative to its linked entities, identifying the functions performed, potential risks, and both tangible and intangible assets utilized.