Biography

Sahid has over 10 years of experience advising clients on international tax matters. Prior to joining Al Tamimi, Sahid worked for a Big 4 in the United Kingdom.

Sahid has a wealth of experience in advising multinational groups on international tax matters in respect of acquisitions, disposals, restructures / reorganizations, expansion into new markets, group holding structures, financing arrangements and legal entity rationalizations.

He frequently advises clients on corporate residency, participation exemptions, permanent establishment risk assessments and withholding taxes on cross border flows. During his time at the Big 4, Sahid was frequently advising clients on complex tax concepts such as anti-hybrid and mismatch rules, controlled foreign company rules and BEPS.

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Recent Experience

  • Advised the KSA Sovereign Wealth Fund on various tax matters including PE risk assessment / management and holding company structures.
  • Supported a multinational video game investment, development, publishing and esports company based in the Middle East on the qualification of the participation exemption.
  • Advised a state-owned petroleum and natural gas company on group holding structures for future investments and profit repatriation.
  • Advising an international drilling contractor on an outward migration ahead of the introduction of BEPS Pillar 2, including pre-exit reorganization and profit repatriation planning, future management of residence and mitigation of PE risk, deemed disposals and compliance obligations.
  • Advised a group on controlled foreign company implications of a legal continuance of a Jersey subsidiary into the US, ahead of the introduction of BEPS Pillar 2.
  • Assisted an insurance provider to rationalize extensive intra group loans with a view to eliminating certain non-active / dormant entities, including the preparation of step plans and balance trackers.
  • Worked with an automotive service group to advise on anti-hybrid and mismatch implications for disregarded entities and loss restrictions following the acquisition of a target group.
  • Restructured intragroup financing for a global veterinary pharmaceuticals group in response to updates made to transfer pricing legislation.
  • Supported a multinational group to restructure its IP ownership in response to anti-avoidance measures. This involved reviewing the group’s existing IP structure, proposing an alternative model and preparing a detailed tax report on the restructuring tax implications.
  • Worked with a listed group looking to simplify its group structure by eliminating dormant entities. The project spanned over a year and involved working with several overseas teams to understand the shareholder and/or target entity tax implications, devising steps to efficiently rationalize the targets and ensuring tax liabilities are minimized.
  • Advised a multinational group on its financing arrangements in response to transfer pricing rules being introduced in a principal financing territory.

Language(s)

  • English
  • Urdu

Education

2009 – International Business Law, University of Manchester (LLM)

Admission

Chartered Institute of Taxation (CIOT)

Practice(s)

Tax

Sector(s)

Insights