Saqib Nafis

A. Due diligence and Tax restructuring

• Tax due diligence for some mega deals, ex: the deal between PIF and STC, Tanmiah Food Company and Tyson Foods, etc.
• Buy-side due diligence, Sell-side due diligence, IPO preparedness for listing in Tadawul or the parallel market (Nomu), on Targets from various sectors such as financial service sector, telecommunication sector, pharmaceutical sector, etc.
• Tax and transaction restructuring with the objective to optimize tax or Zakat in Saudi. Ex: evaluating shareholder loan restructuring options (capitalization, debt refinancing, continue till maturity, etc.)
• Review the tax and indemnity clauses in the Share Purchase Agreement to ensure client’s interest are appropriately covered.

B. International and domestic tax advisory

• Advise foreign entities on the Regional Headquarter (RHQ) initiative in Saudi.
• Permanent Establishment (PE) PE and Force of Attraction (FoA) analysis for a UK based financial institution on their business model in Saudi – ex: agency stock lending, prime brokerage, cash equities model, etc.
• Beneficial ownership analysis under a sale and re-purchase agreement from a tax treaty perspective.
• Inbound tax advisory for non-resident investors in Saudi.
• Fixed place PE, Agency PE and Service PE analysis of the operating model of foreign entities in Saudi.
• Taxability of purchase of software (‘copyright’ vs ‘copyrighted article’) by distributors of products of tech giants (such as Microsoft, Cisco).
• Assist retail operators in the region on structuring their loyalty points program to mitigate tax impact in Saudi.
• Zakat and capital gain analysis of business restructuring carried out in Saudi.

• International tax and domestic tax (including Zakat) for various foreign and local client.
• Tax compliance and litigation support for foreign and local client.
• Key clients: Raytheon, Banque Saudi Fransi , SABIC, BlackRock, General Dynamics Land Systems,