In an interview published by International Tax Review on November 3, 2026, Ramy Torbey, global chairman and managing partner of international law and tax firm Eptalex, reviewed evolving tax frameworks and cross-border structuring across the Middle East following his firm's recognition at the IFLR/ITR Middle East Awards 2026.
Torbey stated that the era of structuring solely for zero tax in the Gulf has ended. He explained that corporate tax, transfer pricing regulations, economic substance rules, and domestic minimum top-up taxes are transforming the Gulf into a formalized tax jurisdiction where economic substance dictates outcomes. In the UAE, the introduction of corporate tax alongside free zone qualifying income rules has expanded transfer pricing scrutiny across regional affiliate transactions.
According to Torbey, client demands have shifted from basic compliance documentation toward active intercompany model redesign, aimed at ensuring structures are defensible simultaneously across jurisdictions including Abu Dhabi, Dubai, and Riyadh. He noted significant focus on cross-border family governance and wealth structures utilizing Abu Dhabi Global Market (ADGM) and Dubai International Financial Centre (DIFC) foundations.
Torbey noted that Eptalex deploys 150 professionals across Beirut, Abu Dhabi, Dubai, Riyadh, Milan, and Istanbul. The firm is directing investment toward private wealth, family governance, international tax, transfer pricing, and fund and regulatory advisory within ADGM and DIFC.
Sources
- International Tax Review · 2026-11-03
