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Cross-border Tax Talks

Pillar Two: Middle East Roundup

22 Dec 2025

Description

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Hanan Abboud, a Dubai‑based International Tax and M&A partner who leads PwC’s Pillar Two efforts across the Middle East. Doug and Hanan discuss the Cooperation Council for the Arab States of the Gulf (GCC) region’s corporate tax landscape, including country differences, Zakat as a covered tax, and the prevalence of withholding and treaty networks. They then map Middle East Pillar Two adoption: Bahrain’s QDMTT, Kuwait’s QDMTT, Oman’s IIR, Qatar’s DMTT plus IIR, the UAE’s QDMTT, and Saudi Arabia’s lack of announcements. They dive into filing timelines, estimated payments, the evolving incentive landscape, the intersection with free zones, as well as practical pain points: data, provisioning, governance, and allocating top‑up taxes. 

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