• Argentina star Lionel Messi trains alone alongside medical officer Javier Hernandez at Qatar University on November 19, 2022 in Doha. Getty
    Argentina star Lionel Messi trains alone alongside medical officer Javier Hernandez at Qatar University on November 19, 2022 in Doha. Getty
  • Argentina's Lionel Messi trains away from the squad. Getty
    Argentina's Lionel Messi trains away from the squad. Getty
  • Lionel Messi walks alongside medical staff member Javier Martinez. Getty
    Lionel Messi walks alongside medical staff member Javier Martinez. Getty
  • Lionel Messi trains away from the Argentina squad. Getty
    Lionel Messi trains away from the Argentina squad. Getty
  • Lionel Messi is watched by the Argentina medical team. Getty
    Lionel Messi is watched by the Argentina medical team. Getty
  • Lionel Messi is put through his paces. Getty
    Lionel Messi is put through his paces. Getty
  • Lionel Messi trains alone from the main squad. Getty
    Lionel Messi trains alone from the main squad. Getty
  • Argentina forward Paulo Dybala (L) watches goalkeeper Emiliano Martinez. AFP
    Argentina forward Paulo Dybala (L) watches goalkeeper Emiliano Martinez. AFP
  • Angel Di Maria and midfielder Rodrigo De Paul. AFP
    Angel Di Maria and midfielder Rodrigo De Paul. AFP
  • Argentina goalkeeper Emiliano Martinez. AFP
    Argentina goalkeeper Emiliano Martinez. AFP
  • Argentina midfielder Leandro Paredes. AFP
    Argentina midfielder Leandro Paredes. AFP
  • Argentina midfielder Rodrigo De Paul. AFP
    Argentina midfielder Rodrigo De Paul. AFP
  • Angel Di Maria of Argentina warms up during the training session at Qatar University. Getty
    Angel Di Maria of Argentina warms up during the training session at Qatar University. Getty

Qatar World Cup predictions: Brazil and Argentina tipped for title, Neymar and Messi shine



The 2022 World Cup is here and the world's best players and national teams are in Qatar to compete for the biggest prize in international football.

Before the big kick-off, The National's sports desk have made their predictions for the tournament.

Jon Turner, Assistant Sports Editor

Champions: Brazil. Strength in depth in every position and a squad packed with stars, Brazil have been a settled squad in fine form for a couple years now. They cruised through qualifying and have a manager in Tite who has his players all on the same page. Brazil are going to take some stopping.

Surprise package: Uruguay. Should advance from their group, of course, but they could pull a Croatia and reach the final, which would qualify as a surprise of sorts. With two of the most in-form central midfielders in the world – Federico Valverde and Rodrigo Bentancur – plus plenty of firepower, Uruguay have the foundations to go far.

Disappointment: England. Woefully out of form and struggling for goals. Manager Gareth Southgate doesn't appear to know his best system nor his best XI, and there are glaring weaknesses in the side. They have the recent pedigree of going deep in the past two major tournaments but no repeat in Qatar.

Top scorer: Kylian Mbappe (France). Full disclosure: Karim Benzema occupied this particular prediction before the Ballon d'Or winner was ruled out with injury, so in steps his fellow strike partner. World Cup top scorer awards are generally secured in the group stage and Mbappe can fill his boots before the knockouts get under way.

Player of the tournament: Neymar (Brazil). Brazil to win the tournament and their talisman to be the star of the show. Heard it here first.

  • Neymar leaves the plane at Hamad International Airport in Doha, Qatar on Saturday, November 19, 2022 as Brazil arrive for the 2022 World Cup. AP
    Neymar leaves the plane at Hamad International Airport in Doha, Qatar on Saturday, November 19, 2022 as Brazil arrive for the 2022 World Cup. AP
  • Brazil's head coach Tite disembarks from an aircraft upon arrival at Hamad International Airport. Getty
    Brazil's head coach Tite disembarks from an aircraft upon arrival at Hamad International Airport. Getty
  • Dani Alves and his Brazil teammates member disembark from an aircraft upon arrival ahead of the World Cup Qatar 2022. Getty
    Dani Alves and his Brazil teammates member disembark from an aircraft upon arrival ahead of the World Cup Qatar 2022. Getty
  • Neymar and the Brazil squad and staff disembark from an aircraft at Hamad International Airport. Getty
    Neymar and the Brazil squad and staff disembark from an aircraft at Hamad International Airport. Getty
  • Brazil players and staff on the bus to take them through Hamad International Airport. Getty
    Brazil players and staff on the bus to take them through Hamad International Airport. Getty
  • Neymar disembarks from an aircraft upon arrival at Hamad International Airport. Getty
    Neymar disembarks from an aircraft upon arrival at Hamad International Airport. Getty
  • Alisson walks towards the bus after disembarking from an aircraft at Hamad International Airport. Getty
    Alisson walks towards the bus after disembarking from an aircraft at Hamad International Airport. Getty
  • Brazil forwards Rodrygo and Antony arrive at the Hamad International Airport. AFP
    Brazil forwards Rodrygo and Antony arrive at the Hamad International Airport. AFP
  • Dani Alves, right, arrives with teammates at Hamad International Airport. AP
    Dani Alves, right, arrives with teammates at Hamad International Airport. AP
  • Brazil players and staff arrive at Hamad International Airport. AP
    Brazil players and staff arrive at Hamad International Airport. AP
  • Marquinhos and teammates arrive at the Hamad International Airport. AFP
    Marquinhos and teammates arrive at the Hamad International Airport. AFP
  • Raphinha and teammates arrive at the Hamad International Airport. AFP
    Raphinha and teammates arrive at the Hamad International Airport. AFP
  • Eder Militao arrives with teammates at Hamad International Airport. AP
    Eder Militao arrives with teammates at Hamad International Airport. AP
  • Gabriel Jesus and Gabriel Martinelli arrive with teammates at Hamad International Airport. AP
    Gabriel Jesus and Gabriel Martinelli arrive with teammates at Hamad International Airport. AP
  • Vinicius Junior arrives at Hamad International Airport. AP
    Vinicius Junior arrives at Hamad International Airport. AP
  • Neymar arrives at Hamad International Airport. Reuters
    Neymar arrives at Hamad International Airport. Reuters

Dominic Hart, Sports Editor

Champions: Brazil. Predictable, maybe, but they are the team in form, are 15 games unbeaten and boast a seemingly endless number of super-talented forwards.

Surprise package: Morocco. With players like Hakim Ziyech, Romain Saiss and Achraf Hakimi in the squad, the Africans have the skill set to scare the life out of anyone on their day. Admittedly, they are in a tough group with Croatia and Belgium alongside the weaker Canada.

Disappointment: France. Injuries are going to be a big problem for many of the favourites, and the French travelled to Qatar at a disadvantage with Paul Pogba, N'Golo Kante, Presnel Kimpembe and Christopher Nkunku ruled out. Benzema was then added to that list on the eve of the tournament.

Top scorer: Cristiano Ronaldo (Portugal). Never one to shun the spotlight, Ronaldo could be looking for a new home after his Manchester United fall-out. Why not use the biggest stage of all to prove Erik ten Hag wrong, and tempt another suitor? If anyone can, Cristiano's the man.

Player of the tournament: Pedri (Spain)

  • Cristiano Ronaldo attends during a training session in Al Shahhniya, Qatar, 20 November 2022. EPA
    Cristiano Ronaldo attends during a training session in Al Shahhniya, Qatar, 20 November 2022. EPA
  • Cristiano Ronaldo during a Portugal training session in Al Shahhniya. EPA
    Cristiano Ronaldo during a Portugal training session in Al Shahhniya. EPA
  • Cristiano Ronaldo attends a Portugal training session in Al Shahhniya. EPA
    Cristiano Ronaldo attends a Portugal training session in Al Shahhniya. EPA
  • Cristiano Ronaldo and teammates take part in a Portugal training session. AFP
    Cristiano Ronaldo and teammates take part in a Portugal training session. AFP
  • Ruben Dias, Bruno Fernandes, Cristiano Ronaldo, and Pepe take part in a training session. AFP
    Ruben Dias, Bruno Fernandes, Cristiano Ronaldo, and Pepe take part in a training session. AFP
  • Portugal coach Fernando Santos watches Cristiano Ronaldo during a training session. AFP
    Portugal coach Fernando Santos watches Cristiano Ronaldo during a training session. AFP
  • Cristiano Ronaldo during training with the Portugal squad. Reuters
    Cristiano Ronaldo during training with the Portugal squad. Reuters
  • Cristiano Ronaldo takes part in a training session at Shahaniya Sports Club. AFP
    Cristiano Ronaldo takes part in a training session at Shahaniya Sports Club. AFP
  • Cristiano Ronaldo arrives for a training session at Shahaniya Sports Club. AFP
    Cristiano Ronaldo arrives for a training session at Shahaniya Sports Club. AFP
  • Soccer Football - FIFA World Cup Qatar 2022 - Portugal Training - Al Shahaniya SC Training Facilities, Al-Shahaniya, Qatar - November 20, 2022 Portugal's Cristiano Ronaldo during training REUTERS / John Sibley
    Soccer Football - FIFA World Cup Qatar 2022 - Portugal Training - Al Shahaniya SC Training Facilities, Al-Shahaniya, Qatar - November 20, 2022 Portugal's Cristiano Ronaldo during training REUTERS / John Sibley

Gareth Cox, Assistant Sports Editor

Champions: Brazil. A boring choice I'm afraid, but cannot see beyond Tite's side. A ludicrous array of attacking talent; a potent mix in squad of youth, experience, and players at their peak.

Surprise package: Denmark. A good group to qualify from with the Danes up against injury-hit France, Australia and Tunisia. Reliable goalkeeper in Kasper Schmeichel, strong defensively and in midfield, although a prolific goalscorer shy of making an even bigger impact on tournament.

Disappointment: France. Another obvious one simply because of the amount of injuries right through the core of the team – Kimpembe, Kante, Pogba and now also Ballon d'Or winner Benzema.

Top scorer: Lautaro Martinez (Argentina). A regular scorer for club side Inter Milan, and his country, Martinez will also benefit by having an in-form – and hopefully fully fit – Lionel Messi pulling the strings alongside him.

Player of the tournament: Neymar (Brazil). Time for the preening show-pony, prone to outrageous dives but with all the talent in the world, to take a tournament by the scruff of the neck and lead his country to glory.

  • France forward Kylian Mbappe during a training session at the Jassim Bin Hamad Stadium in Doha on November 17, 2022, ahead of the 2022 Qatar World Cup. AFP
    France forward Kylian Mbappe during a training session at the Jassim Bin Hamad Stadium in Doha on November 17, 2022, ahead of the 2022 Qatar World Cup. AFP
  • France striker Karim Benzema during training in Doha. EPA
    France striker Karim Benzema during training in Doha. EPA
  • France manager Didier Deschamps with Kylian Mbappe. EPA
    France manager Didier Deschamps with Kylian Mbappe. EPA
  • France's Kingsley Coman is challenged by Lucas Hernandez. Getty
    France's Kingsley Coman is challenged by Lucas Hernandez. Getty
  • Antoine Griezmann of France. Getty
    Antoine Griezmann of France. Getty
  • France goalkeeper Hugo Loris. EPA
    France goalkeeper Hugo Loris. EPA
  • France's player Karim Benzema training with teammates. EPA
    France's player Karim Benzema training with teammates. EPA
  • France attacker Ousmane Dembele. AFP
    France attacker Ousmane Dembele. AFP
  • France attacker Kylian Mbappe. EPA
    France attacker Kylian Mbappe. EPA
  • Fans in Doha watch Karim Benzema at the France training session. EPA
    Fans in Doha watch Karim Benzema at the France training session. EPA
  • France defender Ibrahima Konate. Getty
    France defender Ibrahima Konate. Getty
  • France's Karim Benzema during training. Reuters
    France's Karim Benzema during training. Reuters
  • France attacker Olivier Giroud receives treatment on an injury. EPA
    France attacker Olivier Giroud receives treatment on an injury. EPA
  • France manager Didier Deschamps talks to his players. Getty
    France manager Didier Deschamps talks to his players. Getty
  • France midfielder Aurelien Tchouameni. Getty
    France midfielder Aurelien Tchouameni. Getty
  • France's Karim Benzema watches Raphael Varane. AFP
    France's Karim Benzema watches Raphael Varane. AFP
  • France attacker Ousmane Dembele. EPA
    France attacker Ousmane Dembele. EPA
  • France's Karim Benzema during training. EPA
    France's Karim Benzema during training. EPA
  • France's Karim Benzema. EPA
    France's Karim Benzema. EPA
  • France manager Didier Deschamps talks to his players. EPA
    France manager Didier Deschamps talks to his players. EPA
  • Theo Hernandez of France in action during training. Getty
    Theo Hernandez of France in action during training. Getty
  • France manager Didier Deschamps. AFP
    France manager Didier Deschamps. AFP
  • France forward Antoine Griezmann nutmegs Matteo Guendouzi. Getty
    France forward Antoine Griezmann nutmegs Matteo Guendouzi. Getty
  • The France squad stretch during training. EPA
    The France squad stretch during training. EPA
  • France's Kylian Mbappe. EPA
    France's Kylian Mbappe. EPA

Paul Radley, Reporter

Champions: Argentina. Some bloke called Messi. Forwards of the calibre of Lautaro Martinez and Julian Alvarez. A rugged defence led by Cristian Romero, nicely rested after pulling the ladder up on Tottenham Hotspur for the past few weeks. Plus masses of neutral support in the Middle East.

Surprise package: Qatar. It will be a surprise to many if the host nation do anything at all on the pitch. Yet, thanks to the canny coaching of Felix Sanchez, their Pep Gaurdiola-lite manager, they are far from the easy-beats they once were – as shown by their 2019 Asian Cup title win. An “ooh, they were better than I thought they’d be” surprise package, rather than a title-contending one.

Disappointment: Belgium. Should have plenty in the tank to make it out of a group involving Canada, Morocco and Croatia. But a side with some of the most gilded stars in the sport of recent times might well have peaked. Likely to fall short of the trophy that befits a squad of such enviable talent.

Top scorer: Neymar (Brazil). Brazil’s group is hardly a cakewalk, with Switzerland, Serbia and Cameroon their obstacles to the second round. The Selecao are flying at the moment, though, and their most glittering star should be able to fill his boots in a side not short of firepower.

Player of the tournament: Lionel Messi (Argentina). Was somewhat contentiously awarded the Golden Ball in 2014 after defeat in the final to Germany in Brazil. He could get the vote again this time around if he leads Argentina to the title.

  • Belgium's Kevin De Bruyne in action against Joe Morrell of Wales during the Uefa Nations League Group D match in Brussels, Belgium, 22 September 2022. Belgium won the match 2-1. EPA
    Belgium's Kevin De Bruyne in action against Joe Morrell of Wales during the Uefa Nations League Group D match in Brussels, Belgium, 22 September 2022. Belgium won the match 2-1. EPA
  • Belgium's Kevin De Bruyne, right, goes down as he fights for the ball against Wales' Joe Morrell. AP Photo
    Belgium's Kevin De Bruyne, right, goes down as he fights for the ball against Wales' Joe Morrell. AP Photo
  • Belgium's Kevin De Bruyne. EPA
    Belgium's Kevin De Bruyne. EPA
  • Belgium midfielder Kevin De Bruyne fights for the ball with Wales defender Ethan Ampadu at The King Baudouin Stadium in Brussels. AFP
    Belgium midfielder Kevin De Bruyne fights for the ball with Wales defender Ethan Ampadu at The King Baudouin Stadium in Brussels. AFP
  • Belgium's Kevin De Bruyne celebrates with teammate Michy Batshuayi after scoring to make it 1-0. EPA
    Belgium's Kevin De Bruyne celebrates with teammate Michy Batshuayi after scoring to make it 1-0. EPA
  • Belgium's Kevin De Bruyne, right, and Axel Witsel. AP Photo
    Belgium's Kevin De Bruyne, right, and Axel Witsel. AP Photo
  • Belgium's Michy Batshuayi, right, celebrates with teammates Kevin De Bruyne and Youri Tielemans after scoring to make it 2-0 against Wales. EPA
    Belgium's Michy Batshuayi, right, celebrates with teammates Kevin De Bruyne and Youri Tielemans after scoring to make it 2-0 against Wales. EPA
  • Belgium's Michy Batshuayi. EPA
    Belgium's Michy Batshuayi. EPA
  • Michy Batshuayi of Belgium celebrates after he scores against Wales. Getty Images
    Michy Batshuayi of Belgium celebrates after he scores against Wales. Getty Images
  • Belgium's Michy Batshuayi celebrates with teammates. EPA
    Belgium's Michy Batshuayi celebrates with teammates. EPA
  • Belgium's Michy Batshuayi in action against Rhys Norrington-Davies of Wales. EPA
    Belgium's Michy Batshuayi in action against Rhys Norrington-Davies of Wales. EPA
  • Belgium's Michy Batshuayi, right, fights for the ball against Wales' Rhys Norrington-Davies. AP
    Belgium's Michy Batshuayi, right, fights for the ball against Wales' Rhys Norrington-Davies. AP

Stuart James, Sport sub-editor

Champions: Argentina. It’s a close call between them and the other South American giants, Brazil. On paper, the Selecao edge it in terms of their attacking options, but Argentina landed their first Copa America for nearly 30 years last year and are unbeaten in 36 games. I have a sneaking feeling Messi will sign off his major tournament career by lifting the big one.

Surprise package: Denmark. They made it to the last-16 of the World Cup in 2018, losing out to eventual finalists Croatia, then reached the semi-finals of Euro 2020, where they were beaten narrowly by England. With their star player Christian Eriksen back in the side, they could cause an upset and win Group D against a weakened France.

Disappointment: France. Pogba, Kante, Benzema, Kimpembe, Nkuku out; Varane and Kounde struggling with injury. Even with the depth of talent France can call on, that casualty list – plus the pressure of being defending champions – will prove too much for Didier Deschamps’ men.

Top scorer: Harry Kane (England). Experienced England should again make a deep run into the tournament, with the Spurs marksman profiting.

Player of the tournament: Lionel Messi (Argentina). The PSG superstar will confirm his status as the greatest player of the modern era, while his chief rival Cristiano Ronaldo will disappoint for Portugal.

  • Left to right: England captain Harry Kane with John Stones, Harry Maguire, Callum Wilson, Bukayo Sako and Eric Dier during training at the Al Wakrah Sports Club in Qatar, on Thursday November 17, 2022. Getty
    Left to right: England captain Harry Kane with John Stones, Harry Maguire, Callum Wilson, Bukayo Sako and Eric Dier during training at the Al Wakrah Sports Club in Qatar, on Thursday November 17, 2022. Getty
  • England defender Conor Coady during training in Qatar. PA
    England defender Conor Coady during training in Qatar. PA
  • Left to right: England's John Stones, Harry Kane, Callum Wilson and Marcus Rashford. PA
    Left to right: England's John Stones, Harry Kane, Callum Wilson and Marcus Rashford. PA
  • England's Mason Mount. PA
    England's Mason Mount. PA
  • England attacker Phil Foden during training.
    England attacker Phil Foden during training.
  • England defender Trent Alexander-Arnold, centre, during training. PA
    England defender Trent Alexander-Arnold, centre, during training. PA
  • England captain Harry Kane.
    England captain Harry Kane.
  • England midfielder Conor Gallagher.
    England midfielder Conor Gallagher.
  • England midfielder Declan Rice, centre. PA
    England midfielder Declan Rice, centre. PA
  • England's Phil Foden controls the ball next to Kyle Walker. Reuters
    England's Phil Foden controls the ball next to Kyle Walker. Reuters
  • Left to right: England's Jude Bellingham, Callum Wilson and Kalvin Phillips. Reuters
    Left to right: England's Jude Bellingham, Callum Wilson and Kalvin Phillips. Reuters
  • England's Callum Wilson and Kalvin Phillips. Reuters
    England's Callum Wilson and Kalvin Phillips. Reuters
  • England's Conor Gallagher, centre.
    England's Conor Gallagher, centre.
  • England manager Gareth Southgate with Jack Grealish. Reuters
    England manager Gareth Southgate with Jack Grealish. Reuters
  • England manager Gareth Southgate and his assistant Steve Holland with the players at training. Reuters
    England manager Gareth Southgate and his assistant Steve Holland with the players at training. Reuters
  • England's Declan Rice and Eric Dier. PA
    England's Declan Rice and Eric Dier. PA
  • England's Declan Rice during a training session at the Al Wakrah Sports Club Stadium in Al Wakrah, Qatar. Picture date: Thursday November 17, 2022.
    England's Declan Rice during a training session at the Al Wakrah Sports Club Stadium in Al Wakrah, Qatar. Picture date: Thursday November 17, 2022.
  • England's Raheem Sterling speaks to coach Chris Powell. PA
    England's Raheem Sterling speaks to coach Chris Powell. PA
  • England's Jack Grealish.
    England's Jack Grealish.
  • England's Conor Gallagher.
    England's Conor Gallagher.
  • England manager Gareth Southgate.
    England manager Gareth Southgate.
  • England defender Kyle Walker.
    England defender Kyle Walker.
  • England's Harry Maguire and Harry Kane. Reuters
    England's Harry Maguire and Harry Kane. Reuters
  • General view of England's training session. Reuters
    General view of England's training session. Reuters
  • England's Marcus Rashford runs with the ball towards Callum Wilson.
    England's Marcus Rashford runs with the ball towards Callum Wilson.
  • England's Phil Foden.
    England's Phil Foden.

John McAuley, Reporter

Champions: Argentina. Surely their time. Copa America champions, unbeaten in 36 – alas, the UAE last Wednesday – Messi in incredible rude health and a squad that includes Cristian Romero, Lisandro Martinez, Angel Di Maria and Lautaro Martinez. Battle-hardened, coupled with Messi’s resurgent brilliance (even if Giovani Lo Celso is a sorry miss): perfect timing.

Surprise package: Uruguay. The appointment of Diego Alonso inspired, the effervescence of Federico Valverde and new goal-scorer extraordinaire Rodrigo Bentancur, and that front trio of Luis Suarez, Darwin Nunez and Edinson Cavani. Semi-final run seems set ... if Suarez doesn’t munch anyone, obviously.

Disappointment: France. Only because of the injuries, and the fact England seem a little too obvious. Thought initially the reigning champions would go deep, but then Paul Pogba, N'Golo Kante, Presnel Kimpembe and Christopher Nkunku happened. And, on the eve of the whole thing, Karim Benzema. The current Ballon d’Or holder! Crippling.

Top scorer: Neymar (Brazil). Despite the defeat to their great rivals in the semi-final, Brazil’s main man will have sealed the Golden Boot by that point. Been in fantastic form for club, takes penalties for country. Only three away from becoming his country’s all-time leading scorer. Pele slips to second, but still El Rey.

Player of the tournament: Lionel Messi (Argentina). With Argentina victorious, it has to be their captain. If this is to be Messi’s final World Cup, then hopefully he signs off beautifully. Make the most of seeing a true great on the global stage while you can.

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In numbers

Number of Chinese tourists coming to UAE in 2017 was... 1.3m

Alibaba’s new ‘Tech Town’  in Dubai is worth... $600m

China’s investment in the MIddle East in 2016 was... $29.5bn

The world’s most valuable start-up in 2018, TikTok, is valued at... $75bn

Boost to the UAE economy of 5G connectivity will be... $269bn 

The President's Cake

Director: Hasan Hadi

Starring: Baneen Ahmad Nayyef, Waheed Thabet Khreibat, Sajad Mohamad Qasem 

Rating: 4/5

THE LIGHT

Director: Tom Tykwer

Starring: Tala Al Deen, Nicolette Krebitz, Lars Eidinger

Rating: 3/5

Benefits of first-time home buyers' scheme
  • Priority access to new homes from participating developers
  • Discounts on sales price of off-plan units
  • Flexible payment plans from developers
  • Mortgages with better interest rates, faster approval times and reduced fees
  • DLD registration fee can be paid through banks or credit cards at zero interest rates
Ten tax points to be aware of in 2026

1. Domestic VAT refund amendments: request your refund within five years

If a business does not apply for the refund on time, they lose their credit.

2. E-invoicing in the UAE

Businesses should continue preparing for the implementation of e-invoicing in the UAE, with 2026 a preparation and transition period ahead of phased mandatory adoption. 

3. More tax audits

Tax authorities are increasingly using data already available across multiple filings to identify audit risks. 

4. More beneficial VAT and excise tax penalty regime

Tax disputes are expected to become more frequent and more structured, with clearer administrative objection and appeal processes. The UAE has adopted a new penalty regime for VAT and excise disputes, which now mirrors the penalty regime for corporate tax.

5. Greater emphasis on statutory audit

There is a greater need for the accuracy of financial statements. The International Financial Reporting Standards standards need to be strictly adhered to and, as a result, the quality of the audits will need to increase.

6. Further transfer pricing enforcement

Transfer pricing enforcement, which refers to the practice of establishing prices for internal transactions between related entities, is expected to broaden in scope. The UAE will shortly open the possibility to negotiate advance pricing agreements, or essentially rulings for transfer pricing purposes. 

7. Limited time periods for audits

Recent amendments also introduce a default five-year limitation period for tax audits and assessments, subject to specific statutory exceptions. While the standard audit and assessment period is five years, this may be extended to up to 15 years in cases involving fraud or tax evasion. 

8. Pillar 2 implementation 

Many multinational groups will begin to feel the practical effect of the Domestic Minimum Top-Up Tax (DMTT), the UAE's implementation of the OECD’s global minimum tax under Pillar 2. While the rules apply for financial years starting on or after January 1, 2025, it is 2026 that marks the transition to an operational phase.

9. Reduced compliance obligations for imported goods and services

Businesses that apply the reverse-charge mechanism for VAT purposes in the UAE may benefit from reduced compliance obligations. 

10. Substance and CbC reporting focus

Tax authorities are expected to continue strengthening the enforcement of economic substance and Country-by-Country (CbC) reporting frameworks. In the UAE, these regimes are increasingly being used as risk-assessment tools, providing tax authorities with a comprehensive view of multinational groups’ global footprints and enabling them to assess whether profits are aligned with real economic activity. 

Contributed by Thomas Vanhee and Hend Rashwan, Aurifer

Our family matters legal consultant

Name: Hassan Mohsen Elhais

Position: legal consultant with Al Rowaad Advocates and Legal Consultants.

Updated: November 20, 2022, 11:46 AM