Structuring and tax modelling for greenfield power generation assets and project companies, and their investment holding structures – for commercial and industrial scale assets, as well as larger independent power and water projects.
Tax due diligence support on new oil and gas or power and utility assets, either performing the due diligence or supporting your big4 tax adviser through the review and structuring process.
Advising on broader holding platforms for the portfolio of upstream, non-upstream and renewable energy assets, to evaluate wider tax structuring position, access to tax reliefs and tax efficient repatriation of profits.
Review of tax arrangements under upstream production sharing agreements and other concessions, for local as well as international assets, to evaluate the tax profile and tax exemptions on investment and holding, and advising on suitable special purpose vehicles and holding structures.
Evaluation of exemptions under the UAE CT law for extractive businesses, non-extractive natural resource businesses, and for qualifying infrastructure projects as well as the availability of participation exemption on dividends and capital gains, or qualifying investment fund structures.
We understand how important it is that tax advice is clear and actionable, and takes account of the many, wider commercial and legal considerations.
We would work in all cases with your commercial, legal, and wider finance teams, to develop tax solutions that are appropriate for your business, and that are easy to understand, to implement, and to manage.
We work closely with other tax and legal advisers to bring in additional specialist resources and skills, and jurisdictional coverage, as needed, to provide you with a holistic tax solution for your needs.