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Aquanow and the Future of Digital Finance: A Story of Infrastructure and Innovation

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aquanow

From a Canadian startup to a key player in the global financial evolution

Bridging Two Worlds

While many were retreating from crypto in 2018, three friends with deep roots in capital markets saw something others missed: the foundations of a new financial system taking shape. They founded Aquanow with a bold vision—to build the infrastructure connecting traditional markets with the digital asset frontier.

“Before Aquanow, I was trading equities, focused on the intersection of technology and markets,” says CEO Phil Sham. “We saw early that crypto wasn’t a fad—it was a new asset class where the best parts of finance could be reimagined.”

What sets Aquanow apart is the team’s ability to empathise with clients. “Coming from traditional finance gave us a unique perspective,” explains Sham. “We understood the stringent requirements financial institutions face—from regulatory compliance to risk management. But we were also immersed in blockchain’s innovative potential. This dual expertise allowed us to build bridges between these worlds in a way that pure crypto natives or traditional finance veterans couldn’t achieve alone.”

From Liquidity Provider to Global Infrastructure

Fast forward to 2025, and Aquanow has transformed into a leading financial infrastructure provider with over 120 employees, powering digital asset services for over 300 institutional clients across 50 countries and processing billions in monthly volume.

Today, the company’s comprehensive service offerings are comprised of four essential building blocks:

  • Trade: Advanced trading infrastructure with deep liquidity pools and low-latency execution
  • Pay: Solutions that allow businesses to accept and process digital asset payments
  • Send: Secure and efficient cryptocurrency transfers across platforms and regions
  • Hold: Institutional-grade custody services ensuring maximum security and compliance

This evolution has positioned Aquanow at the center of institutional crypto adoption—particularly in regions embracing digital asset innovation, like the Middle East.

A Foundation of Trust

“When a bank with millions of customers decides to offer crypto services, they’re essentially extending their trust to us,” explains Sham. “We take that responsibility incredibly seriously. Our systems are designed with multiple layers of redundancy, sophisticated security protocols, and rigorous testing methodologies familiar to any enterprise IT department.”

Aquanow’s technology stack features advanced encryption, real-time monitoring systems, and advanced anomaly detection capabilities. The company maintains 99.99% uptime across its core services, with automated failover mechanisms that detect and respond to potential disruptions before they impact end users.

“Compliance isn’t an afterthought for us—it’s built into our DNA,” Sham emphasizes. “From day one, we’ve designed our systems with regulatory requirements in mind, working closely with authorities across multiple jurisdictions to ensure our infrastructure meets or exceeds their standards.”

This proactive approach has been particularly valuable in the Middle East, where authorities are crafting thoughtful frameworks to govern digital assets. Aquanow maintains a dedicated compliance team that continuously monitors regulatory developments worldwide, embedding controls directly into its infrastructure—from robust KYC/AML procedures to real-time transaction monitoring.

The UAE: A Strategic Focus for Growth

Among Aquanow’s global expansion efforts, the United Arab Emirates and wider MENA region have emerged as a particular focus. The region’s progressive regulatory environment and growing interest in digital assets have created fertile ground for innovation.

“Around six years ago, we started expanding internationally, targeting markets with regulatory clarity and strong consumer demand. The UAE checked both boxes,” Sham notes. “I came here about four years ago to begin the licensing process, and since then, we’ve made significant progress.”

That progress culminated in February 2024 when Aquanow received a comprehensive Virtual Asset Service Provider (VASP) license from Dubai’s Virtual Assets Regulatory Authority (VARA)—one of the most extensive awarded to a VASP in Dubai to date.

“Dubai’s Virtual Assets Regulatory Authority has played a significant role,” Sham explains. “They’ve proactively created a responsible oversight framework that allows innovative crypto concepts to become a reality. That clarity and openness have made it easier for companies like ours to build here.”

Powering Emirates NBD’s Crypto Journey

Perhaps the clearest sign of Aquanow’s growing influence is its landmark partnership with Emirates NBD, one of the Middle East’s largest banking groups with approximately $271 billion in assets.

Announced in early 2025, the collaboration enables Emirates NBD’s digital bank, Liv, to offer cryptocurrency trading through its Liv X mobile app—bringing digital asset access to a broad retail audience via a trusted banking platform.

“This partnership enables millions of users to buy and sell crypto like they access other financial services,” says Sham. “With that infrastructure in place, we can start layering on more services—tokenization, payments, cross-border transfers—all the things that blockchain promises but requires a solid foundation to deliver.”

What makes this collaboration particularly significant is Emirates NBD’s century-long history of serving customers in the region. The bank has spent decades building trust with its client base—trust that it’s now extending to digital assets through Aquanow’s infrastructure.

“When we partner with institutions like Emirates NBD, we recognize that they’re entrusting us with relationships they’ve cultivated over generations,” explains Sham. “That’s a profound responsibility. Our infrastructure has to be absolutely bulletproof, because we’re not just supporting a new product—we’re supporting the bank’s reputation and the trust their customers place in them.”

Enabling Crypto Payments in the UAE

While trading is often the first step for institutions entering the digital asset space, Aquanow’s work increasingly focuses on other sources of utility. In February 2025, the company partnered with Hubpay—a leading UAE-based cross-border payments platform—to launch the country’s first fully regulated crypto payment gateway tailored for businesses and SMEs.

The solution enables merchants across industries to accept cryptocurrency alongside traditional fiat, while addressing a major barrier to adoption: volatility.

“Volatility has always been a core concern for businesses considering crypto,” says Sham. “The key is giving them flexibility. Most of our clients aren’t trying to speculate—they want to offer customers the option to pay in digital assets while managing their treasury in fiat.”

Aquanow’s infrastructure supports instant conversion, allowing merchants to settle in either crypto or fiat at the point of transaction. “For example, a real estate developer in Dubai might accept USDC for a property but settle in AED,” Sham explains. “Our job is to remove exchange rate risk and operational friction so businesses can focus on what they do best.”

The Collaboration Ethos

Aquanow operates on the belief that advancing financial services requires close collaboration with existing institutions. The goal is to expand their capabilities while maintaining the trust they’ve built over decades.

“We don’t see ourselves as disrupting traditional finance,” Sham explains. “We see ourselves as enhancing it—providing infrastructure that allows institutions to embrace new technology while staying true to their core values.”

This mindset shapes how Aquanow approaches partnerships. Instead of imposing a one-size-fits-all solution, the team collaborates with each partner to understand their unique needs, constraints, and goals.

“Every institution we work with has its own history, client base, and strategy,” says Sham. “Our role is to provide flexible infrastructure that adapts to their context—not the other way around.”

That same spirit carries through to regulatory engagement. Aquanow works closely with policymakers across jurisdictions, sharing insights to help shape clear, workable frameworks for digital assets, while accounting for regional nuance.

Expanding Access
As Aquanow expands in the Middle East, CEO Phil Sham sees the company’s role as foundational: enabling access, liquidity, and movement across the digital asset economy.

“At its core, crypto is about distribution,” he says. “People need the ability to on-ramp and off-ramp between fiat and crypto. Once that’s solved, everything else—from tokenized assets to borderless payments—becomes possible.”

This vision aligns with the UAE’s ambition to become a global hub for digital finance. Regulatory clarity and rising institutional interest have created a fertile environment—one Aquanow is helping to catalyze.

“Every time a traditional distributor enters the space, they bring thousands—sometimes millions—of users with them,” Sham notes. “That’s where the network effects start. If a fintech in the UAE enables crypto trading and one in the Philippines does the same, we can power remittances between them.”

With large expatriate populations relying on cross-border transfers, the impact is tangible. By reducing cost and complexity, Aquanow’s infrastructure aims to lower friction and expand access to financial services across the region.

The Invisible Infrastructure

As Aquanow continues to expand, the company is guided by a somewhat counterintuitive measure of success: invisibility. The most effective infrastructure, in Aquanow’s view, is infrastructure that users don’t even notice—technology that works so seamlessly that it fades into the background.

“Our ultimate goal is to make the underlying complexity of blockchain technology invisible to end users,” explains Sham. “When someone sends money to family overseas, they shouldn’t need to understand blockchain consensus mechanisms. They should just know that the money arrived instantly, at minimal cost, and with complete security.”

This philosophy shapes how Aquanow designs its solutions. The company focuses relentlessly on user experience, working with its institutional partners to create interfaces that feel familiar and intuitive, even as they leverage the revolutionary capabilities of blockchain technology.

“Traditional fintech wallets and crypto wallets are converging,” Sham observes. “In the future, people won’t need to know they’re using crypto to send money—they’ll just know it works. That’s the direction we’re heading in.”

A Foundation for the Future

Aquanow, once a startup navigating difficult market conditions, has proven its long-term commitment to reshaping financial infrastructure. Through the development of enterprise-grade technology, embedded compliance, and deep institutional collaboration, the company has positioned itself as a key enabler of financial innovation—particularly in markets like the UAE, where trust and transformation go hand in hand.

“The businesses that succeed will be those that move early, build the right partnerships, and stay agile as the regulatory and technological landscape evolves,” says Sham. “We’re proud to provide the infrastructure that makes that possible—secure, compliant systems that let institutions explore digital assets without compromising their core values.”

As the UAE cements its role as a global digital asset hub, Aquanow is helping to turn ambition into execution—bridging the gap between today’s financial system and tomorrow’s possibilities.

Automotive

Chinese Cars Are Reshaping the GCC Market, but Resale Value Could Be the Next Battleground

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The GCC automotive market is undergoing a significant transformation. Chinese manufacturers are expanding their presence, established brands are navigating supply chain disruptions, and consumers are reassessing the economics of vehicle ownership.

At Keyloop Fusion Live Dubai, Srijith KN, spoke with Nour Abu-Safe, Head of Insights & Analytics at AutoData Middle East, about the changing competitive landscape, the impact of regional logistics challenges, and the opportunities emerging for automotive retailers.

Drawing on market intelligence, vehicle valuation data and industry research, she explains why technology alone may not guarantee long-term customer loyalty, why hybrids currently offer stronger residual value, and why the next major opportunity for dealerships could lie in pre-owned Chinese SUVs.

How are disruptions around the Strait of Hormuz affecting established automotive brands, and could the market changes become permanent?

Initially, many believed the disruption would be temporary. However, the data is beginning to show that market conditions are solidifying and businesses are adapting.

Traditional manufacturers, particularly Japanese brands such as Toyota, Nissan and Lexus, are experiencing challenges getting inventory into the region.

Chinese manufacturers have been more agile because several operate their own vehicle carrier fleets and logistics networks. This has allowed them to establish alternative routes into the GCC.

We have seen a 90% reduction in Japanese vehicle imports into the region, linked to the disruption around the Strait of Hormuz.

Alternative routes through ports outside the Gulf and via the Red Sea and Saudi Arabia are increasingly being used. However, these arrangements are creating delays, with vehicles now taking approximately six to eight weeks to reach showrooms.

The important development is that the market is adapting. Some of the alternative logistics routes established during this period could remain in use for years to come.

Are Chinese automotive brands attracting an entirely new generation of buyers, or are they winning customers away from established manufacturers?

It is a combination of both.

Younger consumers, particularly those between 19 and 30, are increasingly attracted to Chinese vehicles because of their styling, advanced technology, competitive pricing and safety features.

For younger families, especially those entering parenthood, these features can be important purchasing considerations.

Chinese vehicles also tend to offer attractive warranty and servicing packages, making them appealing to consumers who want to reduce their overall ownership costs.

Older buyers, particularly those in their 40s and 50s, generally demonstrate stronger loyalty towards established manufacturers and premium brands.

However, Chinese manufacturers are increasingly entering the premium segment as well, and we are beginning to see them capture some of that market share.

These demographic observations are also supported by consumer research, including studies published by YouGov, which we reference in our market analysis.

Chinese vehicles are becoming increasingly sophisticated. But can manufacturers sustain customer loyalty when technology evolves so quickly?

This is one of the most interesting challenges facing Chinese manufacturers.

Advanced technology is a powerful selling point. It looks attractive in marketing materials and helps manufacturers differentiate their vehicles.

However, rapid technological advancement also accelerates depreciation.

When a manufacturer introduces a significantly improved model within a short period, previous model-year vehicles can quickly appear outdated. That creates challenges for residual values and the used-car market.

For dealerships, the opportunity is to identify vehicles that offer a balance between modern technology and proven, practical features.

Hybrid vehicles are an interesting example because they combine improved efficiency with familiar internal combustion technology.

A vehicle that balances innovation with long-term usability may be better positioned to retain customers over five to ten years than one that depends primarily on the latest technology.

Chinese manufacturers are doing many things well, but the next few years will reveal how effectively they manage this challenge.

With affordability becoming increasingly important, how are vehicle financing and leasing models evolving across the GCC?

Vehicle demand remains present, and manufacturers have found ways to maintain supply despite the disruptions.

However, we could see greater pressure on consumer finances over the coming year.

That creates opportunities for financing and leasing providers.

Financing offers with zero down payment are becoming particularly relevant for buyers who may not have sufficient funds available for a substantial upfront payment.

On the leasing side, some operators are reporting demand increases of approximately 30% to 35%.

Consumers still need vehicles for everyday mobility, but some are becoming more reluctant to take on the financial commitment and risk associated with outright ownership.

Leasing offers an alternative that can address those concerns.

What is the biggest opportunity dealerships may be overlooking today that could become particularly important in 2027?

Used Chinese SUVs.

SUVs represent the largest vehicle body-type segment in the region, and the growing population of Chinese SUVs creates a significant opportunity for dealerships.

The first owner typically absorbs much of the vehicle’s depreciation during the initial two to three years. In some cases, that depreciation could be around 50%.

For dealerships, this creates an opportunity to develop certified pre-owned programmes around relatively young Chinese SUVs.

A three-year-old vehicle may still be in excellent condition and covered by its original warranty or service package.

If dealerships can price these vehicles correctly, they can attract buyers who cannot afford a brand-new SUV but still want a modern, well-equipped vehicle.

This could become an important growth segment for the automotive retail industry.

For consumers considering a vehicle purchase today, which offers the strongest proposition: petrol, hybrid, electric or a competitively priced Chinese vehicle?

There is no single answer because the decision depends on individual priorities.

However, when we compare petrol, hybrid and electric vehicles, our current data indicates that hybrids retain their value best.

They offer fuel efficiency while maintaining the familiarity and convenience of an internal combustion engine.

For buyers concerned about long-term value, that makes hybrids particularly attractive.

Chinese manufacturers, meanwhile, are becoming increasingly competitive on design, pricing and technology.

Vehicles such as the ROX 01 and Jetour G700 demonstrate how Chinese brands are entering segments traditionally dominated by established SUVs such as the Toyota Land Cruiser and Nissan Patrol.

The competitive landscape is changing considerably.

One particularly interesting insight from our latest data is that 48% of the new 2027-model vehicles arriving in the UAE are Chinese brands.

That tells us how aggressively these manufacturers are planning their product introductions, expanding supply and positioning themselves to attract both new and existing automotive customers.

The next few years will be particularly interesting as these changes reshape the balance between established manufacturers and emerging competitors.

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The AI Learning Dilemma: Better Answers, But Better Thinkers?

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As artificial intelligence becomes embedded in higher education, universities face a growing challenge: ensuring that students develop independent thinking rather than simply producing polished AI-assisted work. From rethinking assessments to preserving the value of intellectual effort, the conversation is shifting towards what Turnitin calls learning integrity.

In this interview with Amal Dimashki – Regional Director, MENAT & Pakistan, Turnitin explores how institutions can balance AI adoption with critical thinking, meaningful assessment and the development of essential learning skills.

Amal Dimashki, Regional Director – MENAT & Pakistan, Turnitin



Students are becoming increasingly comfortable prompting AI, but how can universities ensure they are still developing independent reasoning and critical thinking rather than simply producing better AI-assisted answers?

Prompting is becoming an important skill, but being able to write a sophisticated prompt is not the same as being able to think critically.

AI can be a very effective learning partner. It can help students brainstorm, explore different perspectives, challenge an argument or receive feedback on something they have written. But students still need to do the cognitive heavy lifting. If they simply prompt AI for an answer and then refine that answer until it looks better, we may improve the quality of the output without necessarily developing the student’s thinking.

This is why AI literacy needs to go beyond teaching students how to prompt. Students need to learn how to critically evaluate AI-generated content, verify information and sources, question what they are given and make their own judgments about the output. Turnitin’s guidance on responsible prompting encourages students to engage with AI iteratively and interrogate its responses rather than simply accepting what it produces.

We want students to use AI as a learning partner while remaining actively engaged in the learning process and taking ownership of the work they produce. Turnitin’s guidance to students reinforces this by encouraging them to ensure that the majority of their work remains their original thinking.

Universities therefore need to develop AI literacy alongside critical thinking and independent judgment, so that becoming better at using AI does not come at the expense of developing the skills students are there to learn.

What should a modern assessment look like if institutions want to measure a student’s actual understanding rather than just the quality of the final submitted work?

In an AI-enabled environment, assessing only the final product gives us a limited view of whether learning actually took place. A polished final submission does not necessarily tell us how the student arrived there.

This is where a process-based approach to assessment becomes increasingly important. Educators can build meaningful checkpoints into the learning journey through outlines, drafts, formative feedback, revisions and reflection. This allows them to see how the student’s thinking developed, how they responded to feedback and where they may need additional support. Turnitin’s multipart assignments, for example, are designed around structured checkpoints for guidance and reflection throughout the writing process.

At Turnitin, we refer to the broader framework behind this as learning integrity. It expands traditional academic integrity by placing greater emphasis on the integrity of the learning process and ensuring that students are doing the work necessary to learn and develop.

It brings us back to a familiar principle: “show your work.” Greater visibility into drafts, revisions and the development of ideas gives educators richer evidence of how a student approached the assignment rather than relying on a single snapshot at the end. Turnitin Clarity, for example, provides visibility into how students develop their work from ideation through to final submission.

This does not mean making every assessment more complicated. It means designing assessment around the learning objective and creating opportunities for students to demonstrate that they have developed the skills being assessed.

The final submission will continue to matter, but it can be considered alongside evidence of the learning process that produced it.

AI makes it possible to get answers, summaries and explanations almost instantly. Do you worry that this could reduce students’ ability to sustain attention, read deeply and work through difficult material without immediate assistance?

There is certainly a risk, and students themselves recognise it. Turnitin’s research found that 64% of students are concerned that the use of AI in education may be shortcutting their learning.

Learning should not become a completely frictionless process. Researching a subject, developing a point of view, articulating ideas with evidence, editing and working through something difficult all require effort, and some of that effort is where learning happens.

Turnitin refers to this through the concept of “productive struggle.” Cognitive growth and long-term retention require students to engage with difficulty rather than having every challenge immediately removed for them.

That does not mean students should struggle without support. AI can provide guidance and feedback throughout the learning process. Turnitin Clarity’s AI Assistant, for example, is designed to prompt reflection and support students throughout their writing without generating the full response for them.

As AI becomes more capable, preserving productive struggle will become increasingly important. We want students to benefit from the support AI can provide without removing the effort involved in developing knowledge and skills.

4. Looking ahead, how do you see the role of academic integrity evolving as AI becomes embedded in writing, research and learning, and what will universities need to change over the next few years?

Academic integrity will remain fundamental, but its role is expanding as AI becomes embedded in learning.

At Turnitin, we describe this evolution through learning integrity, a proactive expansion of traditional academic integrity that places greater emphasis on the integrity of the learning process. It reflects the need to understand how students are developing their work and ensure they are developing the skills their education is intended to build.

Over the next few years, universities will need to translate this into practice. AI governance needs to provide educators with clear guidance, while recognising that responsible AI use will not look the same across every subject or assessment. Turnitin’s learning integrity framework recognises a spectrum ranging from no AI in some contexts to defined AI use cases and more open use in others.

Educators will also need greater agency over how AI is introduced into teaching and assessment. Turnitin’s latest Learning Integrity Insights found that AI decision-making is moving closer to faculty and teaching and learning leaders, while educators are asking for education-specific AI that is flexible enough to reflect how they actually teach and design assignments.

Technology therefore needs to adapt to pedagogy, rather than pedagogy adapting to the technology. This is the principle behind Turnitin Clarity’s configurable AI settings, which allow educators to determine the level and type of AI support appropriate for an individual assignment.

Over the next few years, universities will need to bring these pieces together: clear AI governance, greater educator agency, assessment practices that support learning integrity, and technology designed around the needs of teaching and learning.

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Saudi Arabia’s tax amnesty is entering its final months

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What could follow the December deadline is an assessment cycle, not a filing cycle.

By Manish Bansal, Associate Partner, Dhruva Advisors, A Ryan Affiliate, Saudi Arabia

For most of the past five years, inter-alia, one of the major topics of tax conversation in Saudi boardrooms has been e-invoicing. Are we on the Fatoora platform? Which wave are we in? Has the ERP been configured or do we go with a third-party e-invoicing solution? Will we make the deadline?

Those were the right questions for the period we have just left. They are not necessarily the right questions for the period we are entering.

Manish Bansal

On 29 June 2026, the Zakat, Tax and Customs Authority (“ZATCA”), acting on a decision of the Minister of Finance, extended the Cancellation of Fines and Exemption of Financial Penalties initiative for a further six months, running from 1 July to 31 December 2026. It covers excise tax, value added tax, real estate transaction tax, withholding tax and corporate income tax. That much has been widely reported.

Less widely noticed is a condition set out in the accompanying guideline. If the Authority extends the initiative again past December, that further extension will not reach returns that fell due after 30 June 2026.

The Authority has not simply granted more time. It has informed the market, in advance, where the relief eventually stops. Whatever is announced in December, the clean-up window for historical positions is being drawn shut. For a tax administration, that is about as clear a statement as one can give.

What the regulator already sees

The reason this matters now, rather than in some indeterminate future, is that the Authority’s information position has changed fundamentally.

Wave 24 of the e-invoicing Integration Phase closed on 30 June 2026. Announced in September 2025, it captured every taxpayer whose VAT-subject revenues exceeded SAR 375,000 in 2022, 2023 or 2024. That figure is not arbitrary: it is the mandatory VAT registration threshold. In effect, the wave brought the entire registered population into scope.

And the direction has not stopped there. On 24 July 2026 – ZATCA published the criteria for Wave 25, halving the threshold to SAR 187,500 of VAT-subject revenue in 2022, 2023, 2024 or 2025, with integration required by 1 February 2027.

Under the Integration Phase, standard business-to-business invoices are cleared by ZATCA before they reach the buyer, and simplified business-to-consumer invoices are reported within twenty-four hours. Invoices must be issued in a prescribed structured format, carrying a cryptographic stamp and a unique identifier.

The Authority is therefore no longer reliant on what appears in a filed return. It holds the underlying transactional record, in structured form, close to real time, across the whole economy.

This is the shift most finance functions have not yet absorbed. For years, the Saudi assessment process began with an information request. In an environment of structured, near-live data, it begins instead with an anomaly the system has already identified. The taxpayer’s first substantive contact with the process is not a request for documents. It is a proposition to be answered.

Key exposure areas to be mindful of

In our experience, the following key areas could be more visible and exposed to assessment risk in the Kingdom once transactional data can be cross matched against declarations.

The first is permanent establishment risk arising from project delivery. Groups routinely deploy technical staff, secondees and subcontracted specialists into Saudi projects while treating the arrangement as an offshore supply.  Given that most KSA government portals are inter-linked, careful monitoring of in-Kingdom presence is critical, in particular, employees of non-resident companies undertaking fly-in/fly-out assignments in the Kingdom.  It is worth noting that the current tax law has no de minimis threshold for the creation of a permanent establishment.  Accordingly, even a single day of presence in the Kingdom could potentially give rise to a permanent establishment, although in practice, the ZATCA may apply a more facts-based approach when assessing whether a permanent establishment exists.

Second is related-party pricing, and here a change that took effect two years ago is still under-appreciated. Following amendments to the Transfer Pricing By-Laws, the transfer pricing provisions apply to zakat payers as well as taxpayers for financial years beginning on or after 1 January 2024, and Advance Pricing Agreements became available to both. For a Saudi family group with decades of intercompany arrangements built for operational convenience rather than for documentation, this is a material change in obligation, and one that many such groups have not yet worked through.

Lastly, needless to state that VAT audits are likely to get much more sophisticated with real time data and the data analytics and AI tools available.

What the amnesty covers, and what it does not

Many companies are counting on this window. It is worth being precise about what it covers.

The initiative covers late registration, late payment and late filing fines, penalties on the amendment or correction of a VAT return, and other financial fines imposed under Article 45 of the VAT Law, including field detection and e-invoicing violations. To benefit, a taxpayer must register where registration is required, submit the outstanding returns, and either pay the amounts due or obtain ZATCA’s approval for an instalment plan.

Two limits deserve emphasis. The initiative does not extend to penalties relating to tax evasion violations. And it operates on fines for returns falling due up to 30 June 2026.

There is also a point that no guideline states because it does not need to. The initiative waives penalties. It does not validate a technical position. A voluntary disclosure that corrects an arithmetic omission is a straightforward matter. A voluntary disclosure that reveals a contestable tax treatment is a different exercise entirely, because it puts a position on the record that will be read. The analysis must come before the filing, not after it.

Fewer than four months

For most groups, what remains to be done before 31 December is a short list. It is also, notably, not a systems exercise. The e-invoicing platforms are already built and connected. The work now is reviewing the positions those systems have been reporting all along.

Reconcile first. Take VAT/ Tax/ Zakat returns, customs declarations, withholding tax filings and audited financial statements for the open years and reconcile them against one another before ZATCA’s systems do it. Where the numbers do not tie, understand why, and document the reason contemporaneously rather than reconstructing it under assessment.

Then sort. Separate the genuine errors, which the current window is designed to resolve, from the judgement positions, which need to be assessed on their merits and defended with evidence that pre-dates the query.

Finally, treat documentation as a deliverable with a deadline. Substantiation assembled after an assessment notice arrives carries markedly less weight than substantiation prepared when the transaction occurred.

A regulator that publishes wave criteria six months ahead, that notifies taxpayers directly, that issues guidance with worked examples, and that tells the market in advance where relief will end, is behaving like the administration of a mature investment destination. That predictability is an asset for serious businesses, and it is what long-term capital looks for.

But predictability runs in both directions. The Kingdom has been clear about what it expects and when. The businesses that will move through the coming assessment cycle with least disruption are those that use the next few months to answer the questions before they are asked.

Disclaimer: This article is intended for general information only and does not constitute tax, legal, accounting or other professional advice. It reflects the tax rules in force as of the publication date, and the described regulatory landscape continues to develop. Readers should obtain professional advice appropriate to their own facts and circumstances before acting on any matter discussed.

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