Cross Border Tax Advisory
When your business operates across borders, every decision, where you hold assets, how you move money, where your people are based, has a tax dimension. The rules are complex, they vary by jurisdiction, and they keep changing.
At Sun Management Group, we help businesses operating in and out of the UAE design structures that are efficient, compliant, and built to last, not just optimised for today’s rules.
The Risks of Getting It Wrong
The international tax landscape has also shifted significantly in recent years. BEPS 2.0, Pillar Two, Country-by-Country Reporting (CbCR), and increasing information exchange between tax authorities mean that structures which worked a decade ago may no longer hold up. Proactive planning isn't optional. It's how you avoid expensive surprises, such as:
Double taxation on the same income in multiple jurisdictions
Unintended Permanent Establishment (PE) creation in foreign countries
Denial of treaty benefits including reduced withholding tax rates
Restrictions on cash repatriation due to local tax obligations
Audit adjustments and disputes with tax authorities across jurisdictions
Penalties and interest for non-compliance with filing or withholding obligations
Optimize Your Global Tax Strategy
Our International Tax Services
Cross-Border Structuring
The way you hold assets, route income, and structure entities across jurisdictions determines your long-term tax exposure more than almost anything else. We work with businesses to design and implement group structures that are commercially sound, tax-efficient, and defensible, covering everything from initial market entry through to exit.
Our cross-border structuring support includes:
Group structure optimisation for tax efficiency and operational flexibility
Holding company structuring, jurisdiction selection, and optimal legal forms
IP structuring and migration, royalty flows, licensing models, and substance requirements
Market entry structuring into the UAE for inbound investors
Repatriation strategies, dividends, royalties, management fees, and financing flows
Exit tax planning and cross-border restructuring advisory
Double Tax Treaty Advisory
We help businesses make full, legitimate use of the UAE’s treaty network, from determining eligibility and obtaining Tax Residency Certificates through to structuring transactions to benefit from reduced withholding rates and PE protection.
Our treaty advisory support includes:
Treaty eligibility analysis, qualification and beneficial ownership requirements
Withholding tax optimisation on dividends, interest, and royalties
Permanent Establishment risk assessment and preventive structuring
Tax Residency Certificate (TRC) applications and ongoing management
Substance advisory to maintain treaty eligibility
Inbound & Outbound Advisory
Whether you’re a foreign investor setting up in the UAE or a UAE-based business expanding internationally, the structural decisions you make early on have long-term tax and commercial consequences. We advise on both directions, helping inbound investors choose the right entry vehicle and helping UAE businesses expand efficiently without creating unintended tax exposure abroad.
We support you in both directions: