Based on guidance issued by the relevant tax authorities in the GCC, we hereby provide an overview
of the key considerations and requirements for a transaction to qualify as a TOGC. In this document,
we highlight the relevant rules applicable in each of the United Arab Emirates (UAE), the Kingdom of
Bahrain (Bahrain), the Kingdom of Saudi Arabia (KSA) and Sultanate of Oman (Oman) and analyse
the key differences across the various systems.