Gateley Middle East tax update – Q2 2026

• UAE – Updated Guidance on Family Foundations

Released: 10 June 2026

What happened?

The UAE Federal Tax Authority (FTA) released an updated Corporate Tax Guide on the taxation of Family Foundations, providing further clarification on the treatment of family wealth and holding structures under the UAE Corporate Tax regime.

Our view

This update provides an opportunity for family offices and private wealth structures to revisit and optimise existing arrangements from a tax efficiency perspective, and confirm they remain aligned with both the latest FTA guidance and their broader succession, governance and asset-holding objectives.

Source: FTA Taxation of Family Foundations Guide (CTGFF1) 

• GCC – Amendments to the Unified VAT Agreement

Released: 18 June 2026

What happened?

Amendments to the GCC Unified VAT Agreement were approved, introducing changes relating to intra-GCC supplies, import VAT, information sharing between tax authorities and VAT rate flexibility across member states.

Our view

The amendments further support tax authority cooperation across the GCC and may result in increased visibility of cross-border transactions (especially as the agreement already incorporates information exchange between GCC Tax Authorities). Businesses operating regional supply chains should monitor local implementation measures.

Source: GCC Unified VAT Agreement amendments and implementing resolutions

• Saudi Arabia – Tax Penalty Relief Extended Until 31 December 2026

Announced: 30 June 2026

What happened?

The Zakat, Tax and Customs Authority (ZATCA) recently announced a further extension of the initiative providing relief from certain tax penalties and fines for eligible taxpayers. The extension runs until 31 December 2026 and applies to a range of penalties including late registration, filing and payment penalties, subject to specified conditions.

Our view

While ZATCA have extended this initiative on multiple occasions now, businesses should not assume that further extensions will be granted. The programme continues to provide a valuable opportunity for taxpayers to review historic filing positions, identify any areas of non-compliance and regularise their affairs on favourable terms.

This is particularly important given the potentially significant penalties that can arise during a tax audit or assessment. Companies operating in Saudi Arabia should consider whether the amnesty can be used as part of a broader tax risk review and remediation exercise before the current relief period expires on 31 December 2026.

Source: zatca.gov.sa

• UAE – New Corporate Tax Losses Bulletin

Released: 25 June 2026

What happened?

The FTA published a new Corporate Tax Information Bulletin covering the application of the UAE tax loss provisions and related compliance requirements. The full bulletin can be found here.

Source: FTA Basic Tax Information Bulletin – Corporate Tax Losses.

• Bahrain – First transfer pricing guide issued

Released: 10 June 2026

What happened?

Bahrain released its first transfer pricing guidance in connection with its Domestic Minimum Top-Up Tax (DMTT) framework.

Our view

Transfer pricing continues to be one of the fastest-evolving areas of tax compliance across the GCC. Multinational groups should ensure related-party transactions are supported by appropriate documentation and benchmarking analyses.

Source: Bahrain National Bureau for Revenue publications

• Kuwait Ratifies the OECD Multilateral Instrument (MLI)

Released: 7 June 2026

What happened?

Kuwait ratified the OECD Multilateral Instrument, enabling the implementation of BEPS-related treaty measures across its tax treaty network.

Our view

Groups with Kuwait operations should assess whether the adoption of anti-abuse provisions and treaty modifications could impact existing structures and withholding tax positions.

Source: Kuwait ratification announcement and OECD MLI framework.