Companies that operate across borders have to tackle a constantly shifting tax landscape. The changes are both technical and strategic. Boards, CFOs and tax teams must move from ad hoc responses to systematic preparation. SS &Co recommends clear priorities. These priorities include understanding global minimum tax rules, upgrading transfer pricing controls, preparing for environmental and digital taxes, investing in tax technology, and aligning with trusted advisers. Our Global Corporate Tax advisory practice focuses on these priorities and helps clients translate rules into reliable processes. SSCOGLOBAL also coordinates with accounting and taxation services UAE partners to make sure local reports and international positions match.
The rise of a global minimum tax and its practical effect
The global minimum tax, known as Pillar Two, changes where multinational enterprises pay tax. The OECD designed the rules to ensure a minimum effective tax rate in each jurisdiction where a group operates. Multinationals must now calculate jurisdictional effective tax rates and may face a top-up tax if local rates fall below the agreed minimum. These rules are procedural and mechanical, but they have significant cash and reporting consequences for groups. Companies should review group structures, repatriation strategies and intercompany pricing to limit unexpected top-up tax liabilities. The OECD model rules and implementation guidance are the primary references for this work.
Companies with operations in the UAE should understand how domestic rules interact with the global minimum tax. The UAE’s corporate tax regime introduced in 2023 already changed local tax dynamics and free zone rules. Firms that previously enjoyed low or zero local tax should check how free zone benefits, qualifying income rules and substance tests affect their Pillar Two calculations. SS&Co’s Global Corporate Tax advisory teams work with local accounting and taxation services UAE providers to align statutory filings with international calculations and to ensure that the same set of numbers underpins both local and global compliance.
Transfer pricing, reporting transparency and stronger audits
Transfer pricing scrutiny has increased in parallel with Pillar Two. Tax authorities are investing in transfer pricing capabilities, and the OECD continues to update guidance on hard-to-value intangibles and simplified distribution rules. Countries want unambiguous documents, improved benchmarks, and realistic economic substance in the intercompany arrangements. Moreover, companies should be prepared for performing more thorough audits and facing more frequent data requests that will elucidate the profit distribution among the different parts of the world. Strengthening transfer pricing documentation and aligning it with country-by-country reporting is now a critical control.
Raising standards for tax transparency is another clear trend. Investors and regulators want more granular tax reporting and clearer disclosures on tax governance. Firms preparing for public scrutiny should adopt a tax transparency framework and embed it into their financial reporting processes. SS &Co’s Global Corporate Tax advisory service helps clients design tax governance that meets investor expectations and uses accounting and taxation services UAE firms to produce consistent external disclosures and reconciliations.
Environmental taxes and supply chain levies
Environmental taxes are moving from policy discussion to operational reality. The EU’s Carbon Border Adjustment Mechanism (CBAM) affects imports into the EU and creates reporting and cost implications for global supply chains. Firms that export to the EU need to track embedded emissions, prepare evidence and plan for potential levies or adjustments to pricing. Carbon pricing, eco-taxes and other green levies are likely to spread beyond the EU and will be another dimension of international tax planning. Companies should factor these costs into product pricing and supply chain decisions.
Digital taxes, nexus rules and new sourcing principles
Countries continue to revisit nexus and sourcing rules for the digital economy. While Pillar One aimed at reallocating some taxing rights to market jurisdictions, unilateral digital services taxes or new nexus thresholds remain on many governments’ agendas. Businesses with digital platforms or remote service models must review customer-facing operations, terms of sale and data flows. The design of contracts and the location of servers or sales activities can change where profits are taxed. SS&Co recommends an early review with our Global Corporate Tax advisory experts and with accounting and taxation services UAE teams to ensure accounting systems capture the data needed for any claim of local nexus or market-based taxation.
Compliance burden: more data, more systems, more discipline
The practical cost of global tax change is the compliance burden. Companies must collect high-quality data across legal entities and jurisdictions. They must reconcile financial accounting, management reporting and tax calculations. They must implement controls that prevent data gaps and ensure audit readiness. Tax teams should modernize close processes and integrate tax engines with ERP systems. SS&Co’s Global Corporate Tax advisory work includes designing tax data architectures and operating models. We partner with trusted accounting and taxation services UAE firms to operationalize statutory returns.
Tax function transformation and the role of technology
Technology acts as a force multiplier for tax professionals. Through automation, there is a reduction of human work and an increase in precision for routine computations and submissions. Data lakes, tax provisioning tools and workflow systems are now an integral part of the tax operations in the world. AI can take over the document review and risk scoring tasks, but control and explainability are still the key factors. Partnering with local accounting and taxation services UAE professionals is the best way to keep statutory systems compliant while allowing group-level automation.
People, skills and governance
Tax teams need new skills. Technical knowledge of rules remains essential, but so does data fluency and project management capability. Tax leaders must communicate with finance, legal, treasury, and the board. Governance frameworks should define roles, escalation paths, and tolerances for risk. SS&Co helps firms design tax governance structures and delivery models that balance centralized policy with local execution. Our Global Corporate Tax advisory offering pairs senior advisers with accounting and taxation services UAE specialists to provide both international insight and local execution.
Scenario planning and contingency playbooks
Given uncertainty, scenario planning becomes a strategic tool. Companies should model the possible impact of higher effective tax rates, new levies, or changes in transfer pricing rules. Cash-flow forecasting should include potential top-up taxes and administrative costs. Contingency playbooks for audits, rate changes and treaty disputes reduce reaction time and preserve negotiating leverage. SS&Co builds stress-tested models and playbooks as part of our Global Corporate Tax advisory engagements, and we work with accounting and taxation services UAE teams to ensure local statutory numbers feed into these scenarios.
Practical steps for finance leaders now
Start with a global diagnostic. Finance leaders should identify the entities that are subject to Pillar Two and the other rules, and they should reconcile the statutory accounts with the tax bases used in the global calculations. Transfer pricing documentation should be upgraded and country files should be prepared for submission with supporting documentation. Environmental and digital tax reporting should be integrated where applicable. A tax data architecture and a clear governance model should be adopted.
Conclusion
Global corporate tax trends are converging on transparency, minimum taxation and environmental considerations. The change is structural and long term. Companies that prepare with clarity, data and the right partners will convert compliance into a strategic advantage. SS&Co’s Global Corporate Tax advisory services guide firms through these changes and we work hand in glove with leading accounting and taxation services UAE firms to deliver reliable, audit-ready solutions. Contact SS &Co to arrange a readiness review and a practical plan that matches your business priorities.
