The UK and the UAE have long and deep ties that extend back 50 years. Those ties are built on friendship, cultural and economic relationships. At the heart of the current relationship is the initiative, known as the Partnership for the Future, announced earlier this year by the Prime Minister Boris Johnson and HH Sheikh Mohamed bin Zayed, Crown Prince of Abu Dhabi and Deputy Supreme Commander of the UAE Armed Forces. It is a partnership that embraces 10bn of investment in innovation-led sectors over the next five years that are of strategic importance to both countries.
Open for business
The UK boasts the world’s fifth largest economy and is predicted to continue to grow throughout 2022 and 2023. It is home to over 66 million people, to one of the world’s leading financial centres and Europe’s largest venture capital community, so it is perhaps not surprising that, on average, more than 600,000 new businesses are started in or relocate to the UK every year. Over 2bn has been invested in UK businesses to date, with the UAE accessing world-leading R&D. Companies in the UAE can look to the UK for opportunities to grow where we understand one another business culture. The UK, redefining its position on the world stage following its exit from the European Union and rebuilding post-Covid economy, is open for business.
Why should international businesses choose the UK?
The UAE and the UK has long enjoyed a flow of bilateral business relationships. Many of the cities in the UAE have a large UK expat community, and in turn many UAE citizens come to the UK to live, work and do business. The UK remains the most popular European country for foreign direct investment, attracting some 56.9bn of investment in 2018. Whilst that will have understandably fallen in 2020 due to the global pandemic, the post Covid picture is encouraging and for good reason. The UK offers UAE businesses a world-class legal and regulatory system and a leading financial services environment needed to support growth. It is also home to a strong and forward-thinking advisory community. It is easy to establish a business in the UK, taking on average, just four days yet can be achieved in as little as 24 hours. Businesses are attracted by the flexibility of company structures, low regulatory burdens and the UK’s competitive tax regime.
For many founders, the quality of the UK’s education system, its universities and its cultural pull, together with a highly educated workforce, a time zone that reaches across the globe and its proximity to Europe are all important factors. The UK government works hard to ensure the UK remains competitive on the world stage, offering incentives and grants for businesses looking to grow and expand internationally. Our dedicated grants and funding team at Kreston Reeves is on hand to help. A new visa programme is in place designed to encourage exceptional talent to relocate to the UK, with visa decisions often given in as little as 15 days. Visa routes are also available for business leaders in certain industry sectors, technology being one example, making it easier for founders and their families to establish a UK footprint.
London and the South East
The UK government is proactively encouraging international businesses to relocate across the UK regions, yet it is London and the South East that continue to have the strongest pull. Alongside its renowned financial centre, London is home to Europe’s largest tech hub, TechCity, with a mix of global technology giants and a community of more than 375,000 developers. Venture capital investment into the technology sector reached 7.9bn in 2018, with IPOs and mergers raising over 49bn. The South East is home to thriving life sciences, high value manufacturers, aerospace and IT clusters, naming just a few, attracted by first class infrastructure, a high quality of living and a ready pool of 21m people. Kreston Reeves, with a footprint across London and the South East, is perfectly placed to help relocating businesses find the ideal location.
Competitive tax and regulatory environment
While the UK does not have the same low tax levels as the UAE there is still a good story to tell. The UK Government has announced its intention to increase Corporation Tax rates from the current 19% to 25% from April 2023. Despite this increase, the UK continues to offer businesses a competitive and relatively low rate when compared to other G20 nations. There are generous tax reliefs on research and development (R&D), with Patent Box effectively lowering corporate tax to just 10% on qualifying patented innovations. R&D tax credits can offer up to 230% on allowable research and development for small businesses, and the research and development expenditure credit offers 13% on allowable costs for large businesses. Individuals looking to relocate to the UK can also benefit from significant tax reliefs through the non-domicile regime and with additional reliefs available for those seconded to the UK and apportionment of taxable income if their work is outside of the UK.
Sector strengths
London and the South East offers real strength and depth across many industry sectors that reflect the expertise at Kreston Reeves. London is home to world class financial services and technology businesses, with the city ranked as the most connected place for tech after Silicon Valley. It also boasts a creative industries sector that is valued over 101bn, with TV and film production companies attracted to the expertise offered. The gaming sector is recognised as a global leader. UK Healthcare and life sciences continue to lead the world. London and the South East home to both the largest pharmaceutical businesses and to entrepreneurial biotechnology businesses. The opportunity to partner with the NHS continues to remain a strong pull. The UK and the UAE are aligned in many ways and across many industry sectors. Both countries continue to define business on the world stage and increasingly in partnership.
Why choose Kreston Reeves and the UK
Kreston Reeves is the perfect partner for individuals and businesses in the UAE looking to invest or with business interests in the UK. Our team of highly experienced financial, tax and accounting specialists offer:
We are proud to be appointed by the Department of International Trade, the government body that promotes trade overseas, as one of its champions to help overseas businesses grow. We have been included in the government’s UK Investment Support Directory as one of its chosen experts, in supporting the government’s aim to ensure the UK remains the number one destination for foreign direct investment in Europe.
As the bilateral trade relations between the UAE and Israel are steadily growing, more Israeli companies are looking for major investments in the UAE. According to Prof. Ehud Menipaz, Chairman of International Advisory Committee, Israel Directors Union (IDU) the focus sectors would be Fintech and Digital Security, Food and Agriculture as well as in Energy. He was talking at the “UAE-Israel Business Meet 2021 – A Hybrid Event” hosted by Kreston Menon and Israeli Directors Union (IDU).
Ibrahim Ali, Director of the Investment Promotion Division of Dubai FDI presented the ‘Dubai Advantage’ and invited the Israeli investors to partner with Dubai to shape the future. He interacted with the visiting Israeli delegation of 26 investors in person and with over 200 delegates who attended this hybrid event online.
Jamal Bin Marghoob, Senior Director – Sales, Dubai Airport Free Zone (DAFZA), Faisal Jassim, Senior Manager – Sales, Jebel Ali Free Zone (JAFZA) and Rashid Al Mulla, Vice President – Marketing, Dubai Commercity presented the sector wise advantages that the Free Zones can offer to Israeli businesses. They reiterated rather than being a passive facility provider they are committed to be active partners to the growth and expansion plans of Israeli investors by being a gateway to the world markets.
Dr. Gritt Gur-Gershgoren, Chair of the Chairman Club IDU reiterated that the progress made in the first year of signing the Abraham Accords Peace Agreement, is bound to grow beyond expectations.
According to Shmulik Ben Tovim, President of the Fintech Community of Israel, major partnerships are in the pipeline in the Fintech sector, as Dubai is considered as the region’s hub for financial services and Israel as the tech capital of the world.
Speakers from diverse industry sectors including Banking, Taxation, Real Estate, Legal and Healthcare talked about the investment opportunities in the UAE. Pushpakaran Parambath gave an overview of 100% Foreign Ownership in the UAE while Surandar Jesrani, Managing Partner and CEO of MMJS Consulting made a presentation on the VAT Scenario in the UAE.
Other speakers included Ali Imran, Head of Transaction Banking & Digital Services, Comemrcial Bank of Dubai, Benjamin David Martin, Chief Commercial Officer of VPS Healthcare, Michael Ghaderi, CEO of Aaronz & Co Real Estate, Mohammad Maria, Managing Partner of Just Wills and Gilles Gamon, CEO of BioMeat FoodTech Ltd from Israel.
Doron Rozenblum, Managing Partner of Kreston IL expressed his confidence that more bilateral business partnerships will emerge and Israeli companies with global plans will be looking at UAE as a launching pad.
Raju Menon, Chairman and Managing Partner of Kreston Menon and Sudhir Kumar, Senior Partner and Head of Corporate Communications assured that Kreston Menon, who has supported and guided more than 8000 investors to setup operations in the UAE, will partner with IDU and Kreston IL to promote FDI in both the UAE and Israel.
BACKGROUND
The Transfer Pricing landscape in the Middle East region has been continuously evolving in the last couple of years largely as a consequence of developments arising out of the OECD’s Base Erosion and Profit Shifting (‘BEPS’) project. Several countries in the ME have committed to implement minimum tax standards under the BEPS Implementation Framework (‘IF’), one of which includes Action 13 – TP documentation and Country by Country Reporting (‘CbCR’). As a result, countries such as Bahrain, Egypt, Jordan, Kingdom of Saudi Arabia (‘KSA’), Oman, Qatar and United Arab Emirates (‘UAE’) now have detailed TP and / or CbCR laws in place.
The complexity posed by new laws has meant that businesses operating in the region have more tax thinking to do. It has meant increased TP/CbCR related compliances, more scrutiny/disputes, need to create additional documentation and the need to remodel or do away with existing company structures and intercompany dealings which will no longer work.
The interplay of Transfer Pricing with the Economic Substance Regulations introduced in UAE and Bahrain under BEPS Action 5 – Addressing Harmful Tax Regimes is another factor that can’t be ignored. The more the substance housed in a particular location/entity, the more profits the entity needs to earn. Multinationals have all along made use of UAE & Bahrain’s zero tax regimes to have centralized hubs in terms of headquarter, procurement or intellectual property for their Middle East operations. With the introduction of the first set of BEPS reforms, multinationals in the region have already had to change their strategies but with the upcoming reforms expected as part of BEPS 2.0, their problems will be even more accentuated.
BEPS 2.0
On 1 July 2021, most of the BEPS IF member countries committed to a new overhaul tax reforms referred to as BEPS 2.0 which consist of two Pillars.
Pillar One is initially expected to be applicable only to multinationals with global turnover above EUR 20 billion. It calls for a certain pre-determined share of the consolidated profits of such multinationals to be allocated to markets where proportionate sales arise. Where consolidated profits exceed 10% of revenues, the profit to be reallocated (Amount A) will be 20 to 30% of the excess profit. This profit reallocation is expected to happen regardless of any intra-group Transfer Pricing mechanisms the group may have set in place. Another Amount B aims to set standard margins for group entities that perform low risk marketing and distribution functions.
Under Pillar Two, member countries agree a system whereby multinationals are to be taxed at a global minimum tax rate of 15%. This would apply to groups with global turnover above EUR 750 million (same threshold as for CbCR) but jurisdictions could decide to apply a lower threshold. Pillar Two reforms could manifest as:
The application of Pillar One and Pillar Two appears restricted to the largest multinationals initially however actual implementation needs to be awaited. In addition, certain exemptions areas have been factored under both Pillar Oneand Pillar Two. Initial indications are that both Pillars could become effective as early as 2023.
BEPS 2.0 – ME Impact
Middle East countries such as Bahrain, Egypt, Jordan, KSA, Oman, Qatar and UAE have expressed support for these proposals. UAE in particular issued an official statement issued on 26 July 2021 stating its support for Pillar Two.
Conclusion
For large multinationals operating in the region, firstly we recommend that they track and address all the new country-specific tax compliance requirements that have arisen in the last couple of years and factor in the consequences of non-compliance i.e., adjustments and/or penalties into their tax planning. Secondly, we recommend that businesses be closely aware of the constant developments in the BEPS, TP and CbCR space so they are fore-warned and pre-prepared to develop appropriate future-oriented policies in response to these shifting variables.
World’s Mega Event
The UAE has taken the global center stage with the opening of Expo 2020 Dubai which is termed rightly as the extravaganza of business, technology, connectivity, and culture. One may wonder on the long term objectivity of this mega event, but the policymakers of the UAE are confident about the long term economic legacy the Expo is bound to create.
With 191 country pavilions and themed exhibitions at the Opportunity, Mobility and Sustainability pavilions, the eagerly awaited Expo 2020 Dubai is expected to draw in more than 25 million visitors.
Many countries and large companies are looking to the expo, which is the first major global event open to visitors since the pandemic, to spur economic activity and boost investor confidence.
Expo 2020 Dubai will showcase the latest and boldest innovations across the globe and will be a platform to present solutions to the future for the world in quest for remedies.
UAE – Today and Future
UAE’s approach to future and progress are reflected in the words of His Highness Sheikh Mohammed Bin Rashid Al Maktoum, Prime Minister of the UAE and Ruler of Dubai, “The future belongs to those who can imagine it, design it, and execute it. It isn’t something you await, but rather create.”
The UAE has set its target high to be the numero uno in all the competitive indexes by the centennial anniversary of the Union in 2071. The aspiring national strategy “Towards the next 50” aims to represent the UAE’s next 50 years, building on the foundation of the progress made in the past 50 years.
The roadmap chartered by the UAE for the future includes visionary initiatives like the UAE Centennial Plan 2071, Food Security Strategy 2051, Dubai Clean Energy Strategy, Fujairah 2040 plan, National Advanced Sciences Agenda 2031, Abu Dhabi Economic Vision 2030, Environment Vision 2030, Dubai Industrial Strategy 2031, Plan Abu Dhabi 2030, Dubai 2040 Urban Master Plan, United Global Emirates and Make it in the Emirates and these programs will be guided by the recently announced ‘Principles of the 50′.
Currently, the UAE is placed very high on World Bank’s annual ease of doing business ranking and is always streamlining the processes to better the position. The UAE is the only Arab Country to be listed in the top 10 competitive countries for 4 consecutive years. Dubai has been ranked the fifth best city in the world and was hailed for its innovation, infrastructure, iconic landmarks and world class entertainment.
The credit of the UAE being ranked third among 27 emerging global economies goes to the leadership’s long term strategies on being a testbed for imagining, designing and executing future innovations.
The economic and political environments which are highly conducive for businesses to thrive make the nation a favourable destination for enterprises across the spectrum – from large multinational conglomerates, small and medium businesses to fleet-footed, innovative startups.
The decisive economic measures and new amendments to the residency and investment legislations initiated by the leadership of UAE has stimulated the flow of foreign investments into the country.
The word ‘futuristic’ has become synonymous with the UAE, as a country that not only embraces the future, but courageously create it!
Expo and the UAE Economy
The positive impact of Expo 2020 Dubai, which is arguably the world’s largest event is already visible in almost all the spheres of life, especially among businesses in the UAE. The local businesses are showing immense confidence and strong optimism and the immediate results are seen in key sectors such as travel and tourism and hospitality, with the influx of foreign visitors arriving for the mega event.
The global investment forums, investor pitching conferences and the networking opportunities at the Expo 2020 Dubai is set to create lot of investment interests from across the globe. Even if 0.5% of the visitors decide to invest in businesses in the UAE, we are talking about 125,000 new set ups!
The International Monetary Fund (IMF) has forecasted an economic growth of 3.1% this year for the country, which is higher than the Central Bank’s estimate which projected that the UAE economy will expand 2.1% this year.
The second-biggest Arab economy is expected to reap benefits of the Expo for the next nine years as the Expo legacy is going to drive more international investments. Expo 2020 is expected to give a significant boost of USD33 billion to the UAE economy and is estimated to add more than 900,000 jobs between 2013 (Expo awarded year) and 2031.
UAE’s banking assets are expected to grow by 10% next year, as the Expo has given a much needed impetus to the UAE economy, while other economies are still trying hard to recover from the pandemic-driven slowdown.
A diversified portfolio of public-private partnership (PPP) projects worth more than 25 billion Dirhams was recently announced by Dubai on the sidelines of Expo, which includes projects in the urban development, road and transport as well as health and safety sectors. It is noteworthy that the total value of Dubai’s existing and announced PPP projects now exceeds 65 billion Dirhams. In addition to the fiscal benefits, PPP is a way forward in involving private capital for economic diversification, attracting FDI and promoting local businesses and start-ups, thus help Dubai in creating a sustainable economic growth model.
As the stage is set with the 100% foreign ownership legislation, the visa reforms, ease of arbitration and excellent infrastructure, Dubai is set to see a transformation of industries from fintech to food production. Foreign investments are expected in key sectors particularly those associated with the knowledge economy and advanced technologies which includes Artificial Intelligence, the Internet of Things, Blockchain, innovative medical technologies, high-speed transportation, augmented virtual reality, self-driving cars and renewable energy.
The Expo 2020 will definitely attract more investment and talent to Dubai and the UAE, as this mega show will be showcasing the exciting opportunities not only for entrepreneurs and businesses but also for creative and innovative individuals.
The UK and the UAE share a deep and enduring friendship, built on decades of economic, cultural and people to people ties. This friendship, and the history that we share, lay the foundations for our future relationship.
The UK stands shoulder to shoulder with the UAE as the nation celebrates its 50th year, and looks ahead to the next fifty years. This is why the Partnership for the Future is so important. The Partnership for the Future was announced in September by Prime Minister Boris Johnson and HH Sheikh Mohamed bin Zayed, Crown Prince of Abu Dhabi and Deputy Supreme Commander of the UAE Armed Forces during His Highness the Crown Prince’s visit to the UK.
I was honoured to have taken part in the visit which saw a wide ranging programme of engagement including a business reception at No10 Downing Street, lunch with the Prime Minister, and a number of bilateral Ministerial meetings over two days. One personal highlight for me was seeing His Highness inspecting the guard of honour on Horse Guards Parade.
A Partnership for the Future
The Partnership for the Future encompasses many areas of collaboration from trade and investment to climate change and energy transition to artificial intelligence. At its core, the Partnership addresses two central pillars of great importance to the UK and the UAE: sustainable prosperity and addressing global issues.
Within trade and investment, our countries extended the existing UAE-UK Sovereign Investment Partnership (SIP) signed in March of this year by the UK’s Office for Investment and Mubadala Investment Company. In addition to the £1bn committed when the SIP was launched in March 2021, a further £9bn investment was agreed during the Crown Prince’s visit taking the total to £10bn.
The SIP will serve as the framework of our future-focused investment relationship. Over a five-year period, the SIP will invest across four key innovation-led sectors – technology, infrastructure, healthcare & life sciences, and clean & renewable energy – that will support job creation in both countries, strengthen national research and development capabilities and originate new areas of investment collaboration. These sectors were selected because they are of strategic importance to both countries as we address the challenges of today and tomorrow. Indeed, the UAE has already committed over £1.1bn across 12 transactions and we have visibility on a further £1bn this year, taking 2021 investment to over £2bn.
The UAE will gain access to world leading R&D in the UK. It provides a channel for the UAE to invest in tomorrow’s unicorns as well as encouraging more UK firms to establish a presence in the UAE in sectors that matter to the UAE’s economic plans.
For the UK, which is the leading destination for investment in new projects in Europe (EY UK Atrractiveness Report, June 2021), the SIP will provide much needed investment to drive R&D, provide a further source of growth capital for emerging firms, and ensure UAE investment aligns with UK priorities of attracting investment to all four corners of the UK.
A major focus of the SIP is identifying opportunities that benefit the whole of the UK, particularly outside London and the South East including Scotland, Wales and Northern Ireland. Greater investment in the UK’s industries of the future will create high-value jobs, boost the economy and level up the country as we build back better and greener.
Creating trade and investment foundations for the next 50 years
As the UAE celebrates its 50th year, the exchange of knowledge, innovation and ideas resulting from the Sovereign Investment Partnership will lay the groundwork as the nation looks ahead to the next 50 years.
The UAE’s Principles of the 50 is the strategic roadmap for the next fifty years, and hold important synergies with the UK’s levelling up agenda and our strategy to Build Back Better. Part of the Principles of the 50 includes the 10×10 goal to increase the UAE’s exports to ten key global markets – including the UK – by 10% per annum for ten years, and we look forward to supporting businesses in the UAE to achieve this.
While 2020 saw a drop in global trade figures, I look forward to the resumption of strong trade between the UK and the UAE, which saw a total of £18.6bn of bilateral trade in 2019.
When you look at the UAE’s economic roadmap for the coming decades and the UK’s growth industries, there’s a clear opportunity for our nations to be deeply linked as trade, investment and innovation partners.
Innovating for a Shared Future at Expo 2020 Dubai
This is clearly in evidence when we look at the UK’s engagement in Expo 2020 Dubai. Not only did the UK openly support Dubai’s bid for Expo 2020 back in 2011, it was also host to the Great Exhibition in 1851, the very first Expo if you will.
We are extremely proud of the UK Pavilion at Expo 2020 Dubai, and I am delighted to share some highlights with Kreston Menon News.
The building itself was conceptualised by Es Devlin OBE, and inspired by one of Stephen Hawking’s final projects, ‘Breakthrough Message’, where Hawking challenged the world to design a message representing Earth, life and humanity that could potentially be understood by another civilisation with the aim of encouraging us to think together as one world. Devlin took the concept further, drawing on the UAE and the UK’s shared history of poetry. Her idea was to invite humanity to create a poem using the power of Artificial Intelligence that could be beamed to outer space from Dubai.
Innovating for a Shared Future is the UK’s theme at Expo 2020 Dubai, and Artificial Intelligence underpins the UK Pavilion’s offer. The Pavilion will display AI technology first-hand, using a bespoke algorithm to generate poetry from contributed words. Crafted and designed by thought leaders and industry experts, and trained with thousands of poems, this unique technology will demonstrate the power of UK AI innovation.
Among the most notable elements of the UK Pavilion during the six-month long Expo will be the immersive Choral Space, where visitors will be surrounded by the Soundscape: music, voices and sounds donated from around the world. Visitors can contribute a word to the poem generated by our AI algorithm, which will be on display at the UK Pavilion. The poem will be known as the Collective Message and I hope all Kreston Menon readers will contribute to it, in person or virtually.
The UK Pavilion structure is simply stunning, and a truly accurate representation of Devlin’s vision.
Breakthrough Moments
The power of innovation is the driver behind the UK Pavilion’s Breakthrough Moments – a series of eight thought-provoking questions about our future designed to spark discussion around the world’s most pressing issues. These eight questions – which include How will we Travel?, What will we Eat? and How will we Thrive? – form the foundations of our programme, which will comprise exhibitions, panel discussions, seminars, podcasts, summits and much, much more.
Speakers from the UK and across the globe have been invited to contribute to the Breakthrough Moments, which will feature leaders and experts from a wide range of industries including fashion, design, technology and sustainability, showcasing the best of UK innovation. The UK Pavilion’s contribution will be presented alongside the 191 nations participating at Expo 2020 Dubai. Find out more about the Breakthrough Moments on the UK Pavilion website.
All this and more await you at the UK Pavilion.
I hope to see you there.
Photo Credit: WAM.ae