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GCC TRANSFER PRICING TIGHTENS IN 2026 AS ENFORCEMENT MATURES

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Executive from Dhruva Consultants standing in a modern office corridor, wearing a dark business suit and red tie, with glass meeting rooms and workspaces in the background.

Dhruva, a tax advisory firm with deep expertise across the Middle East, and global markets, stated that the Gulf Cooperation Council (GCC) is at a clear inflection point in its fiscal evolution. Transfer pricing is moving beyond first-wave rulemaking into an enforcement-led environment where it is increasingly treated as a core element of corporate governance.

Drawing on the UAE Year in Review 2025 report recently launched by Dhruva, the region is moving past inaugural filing seasons and confronting the limits of reactive, post-facto compliance. “The past year has been transformative, representing not merely technical adjustments but a strategic recalibration of the region’s economic architecture,” said Nimish Goel, Leader, Middle East at Dhruva. In this environment, the behavioral reality of a business must align with its legal documentation, as tax authorities raise expectations around demonstrable economic substance.

A central theme in this scrutiny is Key Management Personnel (KMP). Where decision-making occurs, who exercises control, and how governance is evidenced are becoming determinative factors in how profits are attributed and defended. Inconsistencies across HR contracts, organization charts, board minutes, operational reality, and transfer pricing files are increasingly treated as a credibility gap, not a documentation error.

This recalibration is being accelerated by a shift in audit approach. Tax authorities across the GCC are moving from form-based reviews to more sophisticated, data-led scrutiny. Kapil Bhatnagar, Partner at Dhruva, stated that, “A key focus is the ‘invisible backbone’ of many regional groups, common-control and related-party transactions that sit at the heart of multilayered conglomerate structures. Informal arrangements historically treated as low-risk are increasingly being evaluated through an arm’s length lens, including interest-free shareholder loans, uncharged centralized services, legacy intercompany balances, and balance-sheet support. For forward-looking organisations, transfer pricing is no longer a compliance obligation but a strategic enabler.”

In parallel, the UAE has signaled stricter arm’s length expectations for Qualifying Free Zone Persons, with transfer pricing increasingly functioning as the mechanism through which substance is demonstrated under the Corporate Tax regime.

The stakes are further elevated by Pillar Two global minimum tax developments. Effective 2025, most GCC jurisdictions, including the UAE, Qatar, and Bahrain, either implemented or were in the final stages of implementing Domestic Minimum Top-up Taxes (DMTT). Under these rules, intercompany pricing can no longer be treated purely as a compliance variable, since it can materially influence a group’s effective tax rate and potential top-up exposure.

“In response, leading groups are shifting toward operational transfer pricing, embedding pricing policies into ERP workflows to improve year-round accuracy, data integrity, and audit readiness. This is increasingly relevant as audits begin to rely more heavily on data analytics, ERP trails, and transaction-level evidence, with deeper linkage expected between transfer pricing documentation, financial statements, tax returns, and support evidence,” added Kapil.

At the same time, demand is rising for certainty and dispute-prevention mechanisms, including Advance Pricing Agreements (APAs) and Mutual Agreement Procedures (MAPs), particularly for complex cross-border arrangements where predictability is commercially valuable. The UAE has already established a formal framework for clarifications and directives including APAs, confirmed unilateral APA applications from Q4 2025, and introduced a schedule of APA fees effective from January 1, 2026.

As the region moves into its next phase of maturity, Kapil concluded, “The message is clear, the era of fixing and filing is over. The era of governance, digitization, and transparency has begun.”

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Financial

INSIDE THE NEW RISK REALITY FACING GCC TRADE AND LOGISTICS

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Exclusive interview with Aurélien Paradis, CEO of AU Group MEA

How Supply Chain Disruptions Are Reshaping Trade Across the GCC?

What we are seeing across the GCC is a reset in how trade moves. Goods are still flowing, but the routes, timelines, costs, and risk assumptions behind them are changing. That is the real shift businesses are now dealing with. The pressure on key shipping corridors has forced companies to rethink the way they move goods across the region. Many are having to re-route shipments, work with a wider mix of logistics partners, and rely more heavily on alternative models such as land bridge solutions or sea-air combinations. At the same time, higher freight costs, with carriers introducing surcharges ranging from USD 1,500 to USD 4,000 per container, rising insurance premiums, and longer transit times, with the rerouted sailings adding around 10- 14 days, are putting additional pressure on already tight supply chains.

For businesses in the GCC, this creates a very different operating environment. Essential imports, raw materials, and industrial inputs may still arrive, but not with the same predictability companies were used to. And once predictability is lost, the impact is felt well beyond logistics. It affects project timelines, inventory planning, customer commitments, and ultimately working capital. Even with the re-opening of the Strait of Hormuz, it will take time to make-up for the delays. So, the real story is this: trade in the GCC is continuing, but under a new risk and cost structure. Companies that adapt fastest, by building more flexibility into sourcing, transport, and risk planning, will be in a much stronger position than those still relying on old trade assumptions.

Why GCC Companies must Rethink Credit Risk in a Volatile Trade Environment?

At its simplest, trade credit insurance exists to protect a business when a customer cannot pay for goods or services. It is built on a basic commercial truth: a sale is only complete when the cash is collected. In more stable conditions, many companies treat that risk as manageable and assume late payment can be absorbed. The problem today is that volatility is changing the risk much earlier in the trade cycle.

Receivables are often one of the largest assets on the balance sheet, so when they come under strain, the effect is immediate on cashflow and working capital. The stronger businesses will be the ones that reassess buyer quality earlier, stay closer to payment behaviour, and act before stress becomes loss. In this environment, protecting the receivable is just as important as moving the goods.

Why Trade Credit Insurance Is Gaining Importance in the GCC

Because businesses are operating in a market where uncertainty is no longer occasional; it is becoming part of the trading environment itself. In that kind of climate, companies are paying closer attention not just to how much they sell, but to how securely they can sell on credit. The value of trade credit insurance is that it does not only protect against non-payment. It also gives businesses a more informed view of the customers they are trading with and the level of exposure they are carrying. That becomes particularly important when supply chain disruption, rising costs, and liquidity pressure can weaken a buyer’s position quite quickly.

What is changing is the way companies are looking at the tool. It is no longer seen only as a defensive measure used after something goes wrong. More businesses are using it as a way to trade with greater confidence, protect cashflow, and make better credit decisions while conditions remain volatile. It can also strengthen access to financing, because insured receivables are often viewed more positively by lenders. In that sense, trade credit insurance is gaining relevance not only because risk is rising, but because it helps businesses stay commercially active without taking unnecessary exposure. The companies that understand this are treating it less as a safety net and more as part of a stronger growth strategy.

What are the biggest logistical challenges currently affecting GCC businesses?

The biggest issue at the moment is that companies are not facing just one logistical challenge, but the piling up of several at once. Businesses are dealing with route disruption, longer transit times, capacity pressure at alternative ports, customs and documentation delays as cargo is redirected, and higher transport and insurance costs as carriers adjust to a more volatile operating environment. Even when goods can still move, they are not always moving through the most efficient or predictable channels, which makes planning far more difficult for importers, distributors, and project-led businesses. That loss of predictability is often the most disruptive part, because it affects everything from inventory timing to delivery commitments and resource allocation.

What can make things more serious and with a lasting impact is the scale and the duration of the disruption. In practical terms, that means companies must now incorporate higher risk for rerouting, and delays rather than treating them as exceptions in the GCC region. The businesses managing this best are the ones increasing flexibility in routing, diversifying logistics partners, and planning for disruption as a recurring operating condition rather than a temporary shock

Q5. Which sectors are most vulnerable to supply chain disruptions?


Several industries across the GCC are feeling the sharpest impact from current supply chain disruption, particularly those that rely heavily on global shipping routes, imported inputs, or time-sensitive delivery cycles. Food and FMCG remain among the most exposed, especially within the cold chain, where fresh produce, meat, dairy, and other perishables depend on strict timing and uninterrupted movement. Manufacturing and industrial sectors are also under pressure, as delays in raw materials and inbound components can slow production, raise inventory costs, and strain working capital.

Construction and building materials face similar challenges, with many projects across the region dependent on imported supplies, meaning longer transit times can lead to delays, cost overruns, and pressure on already demanding timelines. Energy-linked industries are not immune either, as refinery inputs and critical equipment still move through affected shipping lanes. Automotive, electronics, and retail have also been hit by detours around Africa, which are creating shortages and pushing out delivery schedules for consumer goods.

At the same time, SMEs across all trading sectors remain especially vulnerable, as thinner margins and lower liquidity leave them less able to absorb delayed settlements or sudden disruption. Despite these pressures, the region remains highly resilient, and one clear outcome of the current environment is that businesses are being pushed toward stronger supply diversification, tighter financial discipline, greater use of credit risk tools, wider adoption of trade credit insurance, and more serious investment in supply chain agility.

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MOZN’s AI-Powered FOCAL Platform Earns Recognition in Forrester Financial Crime Landscape

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MOZN, a leading enterprise AI company, today announced that it has been named among notable vendors in Forrester’s Financial Crime Management Solutions Landscape Q1 2026 report. This inclusion marks a significant milestone for MOZN and reinforces its position among global innovators.


The Forrester report, which lists 42 vendors, provides financial institutions with an overview of notable vendors and the key market dynamics shaping the rapidly evolving financial crime management (FCM) market, including fraud and anti-money laundering (AML) solutions.


MOZN was listed in the report with a geographic focus on Europe, the Middle East, and Africa (EMEA) and the Asia-Pacific (APAC) regions, and an industry focus on financial services, government, and insurance. The recognition underscores the company’s sustained investment in AI-driven innovation and its focus on delivering scalable, future-ready financial crime solutions tailored to high-growth and complex regulatory markets.


At the center of this recognition is FOCAL, MOZN’s end-to-end financial crime management platform. Built on a unified FRAML (Fraud + AML) architecture, FOCAL leverages agentic AI to automate data integration, accelerate risk-scoring, and streamline alert triage, enhancing investigator productivity while preserving human judgment. The platform offers flexible deployment options, allowing organizations to modernize their operations in a way that aligns with their technical and regulatory needs.


“MOZN’s inclusion in Forrester’s report reflects the progress we have made in building technology that truly transforms how institutions combat financial crime,” said Dr. Mohammed Alhussein, Founder and CEO of MOZN. “As Saudi Arabia designates 2026 as the Year of Artificial Intelligence, it reinforces the Kingdom’s ambition to lead in shaping the future of AI globally. At MOZN, we are proud to contribute to this vision by engineering AI-native platforms that make financial crime prevention more proactive, precise, and effective. This milestone reflects both the momentum of our mission and the growing global relevance of technology built in the region.”


By combining deep regional expertise with global technology standards, MOZN continues to advance its purpose of empowering organizations with intelligence that matters. The company remains committed to delivering AI-native solutions purpose-built for the world’s most regulated and knowledge-intensive sectors, enabling institutions to operate with greater clarity, confidence, and control. As demand for advanced AI-driven capabilities accelerates worldwide, MOZN is expanding its global footprint, supporting organizations as they navigate an increasingly complex financial crime landscape.

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THE INFORMATION PARADOX IN MODERN MARKETS: WHY MORE DATA DEMANDS BETTER JUDGEMENT

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By Roberto d’Ambrosio – CEO at Axiory

Financial markets in 2026 are producing more information than at any point in history. Earnings data, geopolitical alerts, AI-generated analysis, social media commentary, and real-time price feeds reach investors continuously, relentlessly, and from every direction. The conventional assumption is that this abundance is empowering. More data, the argument goes, means better-informed decisions. From my experience across more than three decades in financial services, the reality is considerably more complicated, and for many investors, the opposite is closer to the truth.

Access to information is not the same as the capacity to process it. When data exceeds the ability of the individual to filter, interpret, and act on it with clarity, the result is not better decision-making. It is hesitation, reactive behaviour, and a false sense of confidence that having seen the data is the same as having understood it. Research published by the Board of Governors of the US Federal Reserve has confirmed what practitioners have long observed: information overload is associated with lower trading volumes and measurably higher risk premia, as investors demand greater compensation for holding assets in an environment where they can no longer reliably distinguish signal from noise. The effect is not marginal. It is structural, and it worsens precisely when markets are most volatile and when clear thinking matters most.

This is particularly relevant for the Middle East. The GCC’s retail investment sector has expanded rapidly, with neo brokerages and digital trading platforms now comprising a market valued at approximately $1.2 billion. The UAE’s regulatory framework, spanning the Securities and Commodities Authority, the Dubai Financial Services Authority, and the Financial Services Regulatory Authority, sets meaningful standards for disclosure and investor suitability. Yet the sheer volume of unfiltered data reaching individual investors through apps, alert systems, and AI-driven content is outpacing the governance infrastructure designed to protect them. Earlier this year, UAE-based retail platforms reported a sharp spike in commodity trading volumes following geopolitical alerts linked to regional energy infrastructure. The pattern was instructive: investors were not responding to analysis. They were reacting to the noise itself.

In my opinion, the real competitive advantage in today’s markets has shifted decisively. It is no longer about who has access to data, because everyone does. It is about who has the discipline, the frameworks, and the human capacity to determine what that data means and what it does not. This is fundamentally a risk management challenge, not a technology challenge.

Consider the consequence chain. When platforms deliver thousands of data points, alerts, and AI-generated recommendations without adequate curation, they create an illusion of informed participation. Investors who lack the training or advisory support to contextualise this information face two symmetrical risks: paralysis, where conflicting signals prevent any decision at all, and impulsive reaction, where a single alarming headline triggers an unexamined trade. Both degrade portfolio outcomes. Both increase transaction costs, erode returns through poorly timed decisions, and expose investors to risks they have not consciously chosen to take.

This raises an uncomfortable question for data providers and platform operators. The business model of much of the fintech and financial information industry is built on engagement, meaning more alerts, more content, more interaction. But engagement is not the same as service, and information delivery without responsibility for its quality, context, and potential impact on decision-making is not a neutral act. It carries consequences, and regulators are beginning to recognise this.

The European Union’s AI Act, whose high-risk obligations for financial services take effect in August 2026, will require providers of AI-driven systems used in credit scoring, risk profiling, and investment decision-making to meet strict standards around transparency, human oversight, and auditability. The EU’s proposed Financial Data Access regulation extends similar principles to data sharing across the financial sector. These frameworks signal a clear direction: those who provide financial data and algorithmically generated analysis will increasingly bear responsibility for how that information is presented, contextualised, and governed. For the GCC, where regulators have consistently demonstrated a commitment to adopting and adapting international best practice, the trajectory is evident. Data provision is moving toward becoming a compliance-intensive activity, and firms operating in or serving the region should prepare accordingly.

But regulation alone will not solve the information paradox. Compliance frameworks establish floors, not ceilings. The deeper challenge is cultural and organisational. Investors, whether institutional or individual, need not just data but the capacity to interpret it within a coherent risk framework. Before acting on any data point, alert, or algorithmically generated recommendation, the prudent investor asks three questions: what is the source, what context is missing, and does this information warrant action or merely attention? This discipline is not intuitive in a market designed to reward speed, but it is essential. It means investing in financial literacy, in advisory relationships grounded in trust and expertise, and in governance structures that ensure decisions are informed by judgement rather than driven by impulse.

Ultimately, this is a human capital challenge. Algorithms can process data at scale, but they cannot replace the informed professional who understands context, identifies what is missing from the data, and exercises the judgement to act, or equally important to refrain from acting, when conditions are uncertain. Organisations and platforms that invest in experienced risk professionals, in robust advisory capability, and in the governance to ensure quality over quantity will build durable competitive advantages. Those that continue to prioritise data volume over decision quality will find that the market eventually prices that negligence in.

In a market flooded with information, the scarcest resource is not data. It is the judgement to know what to do with it.

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