Profile

Zain Satardien is a Partner and Head of Tax and International Trade practice group at Hourani & Partners. With nearly two decades of experience, Zain’s core practice lies in blending his expertise in GCC tax law, international trade law, corporate structuring, legal strategy and litigation.

Drawing on his extensive experience in these disciplines, Zain regularly provides legal and strategic advice to both private sector clients and public sector institutions in the GCC. He regularly advises both regional and international clients, as well as governmental entities, multinationals, family offices, and corporate clients. He advises on a range of issues centering around tax law, trade law, investment law, corporate and tax structuring, and related litigation.

Chambers and Partners has acknowledged that “Zain possesses a unique blend of expertise and experience that is rare to come across in the market”, “is very knowledgeable about … strategy”, and “demonstrate[s] the highest level of professionalism and precision”.

Zain is also a Lexis Nexis award-winning author and recently published a book titled ‘Global Trade Law in the Middle East: Essential Principles for the Gulf States’. First of its kind, the book offers to present concise and practical guidance on the international trade law framework of the GCC.

Prior to joining Hourani & Partners, Zain served as a senior member of Ernst & Young’s EMEIA Tax Centre Global Trade advisory in Dubai. Prior to this, he served in senior legal positions as head of legal in government tax and trade authorities.

Expertise
  • Tax Law (Corporate Tax, Income Tax, Zakat, Withholding Tax, RETT, VAT, Excise Tax, ESR, Transfer Pricing, PE, FATCA, Pillar 2, Private Wealth Tax, etc.)
  • International Trade Law, Customs Law, WTO law, Trade Agreements and Related Advisory
  • Tax, Corporate, Legal and Wealth Structuring
  • Cross-Border Tax and International Trade Strategic Negotiations and Disputes
  • Related Litigation
Experience

Zain’s experience includes advising:

  • A well-established Saudi conglomerate on the most corporate and tax efficient structure regarding the sale of business assets and real estate, which required careful consideration to avoid double payment of real estate transaction tax, and VAT.
  • A leading engineering company on group tax structuring across the GCC in connection with corporate income tax, transfer pricing, withholding tax, zakat, capital gains and VAT, with advice spanning across 6 jurisdictions.
  • A major British multi-national company in relation to compliance with the new and technical laws and regulations concerning imports and exports of its product from the UAE to other GCC countries.
  • A UK multi-national FMCG client that required litigation services in Saudi Arabia in connection with potential adverse action from the Saudi customs authority, which included advising on customs duty exemptions based on the GCC and World Trade Organization (WTO) rules of origin.
  • A major Swedish furniture company on customs valuation and a royalties dispute with a GCC tax authority which escalated to World Customs Organization.
  • Large GCC and MENA clients on corporate structure setups and efficient tax planning as part of transactions in various industries including F&B, banking, financial services, telecommunications and education as well as assisting large national sovereign wealth funds.
  • A major GCC-based distributor on transfer pricing regulations and related party risks, including aspects on effective control via business, debt and management, legality and tax implications interest loan advancing, including withholding tax implications on payments between related/affiliated entities.
  • A US multi-national conglomerate on a matter that overlapped on two highly technical and separate legal aspects of WTO and GCC treaty rules on customs valuation, as well as OECD and local UAE and Saudi Arabian rules on tax and transfer pricing.
  • A UAE client in a litigation matter for cancellation of contract for the purchase of goods from a UK- and US-sanctioned Russian enterprise.
  • One of the world’s largest accounting firm’s clients on the tax law, global trade and customs law regimes in the GCC.
  • Major multi-national clients in two separate transfer pricing tax law disputes in Saudi Arabia, in which our clients were successful on both counts.
  • A multi-national client in nine separate VAT law disputes, in which our clients were successful in seven.
  • Conducted comprehensive analysis to optimize supply chain structure for trade, customs and tax efficiency, mitigating risks and ensuring a viable agreement for our client. Identified significant potential liabilities overlooked by the supplier’s proposal, offering alternative models to empower the client in negotiations and secure a more favorable, risk-mitigated deal.
  • A leading engineering company on group tax structuring across the GCC in connection with corporate income tax, transfer pricing, withholding tax, zakat, capital gains and VAT.
Qualifications

Education

  • Currently completing Doctor of Laws in WTO Customs Valuation and Transfer Pricing law, University of Pretoria, South Africa
  • Advanced Professional Certificate in International Taxation (IBFD)
  • LLM, Dispute Resolution Law (distinction), University of Missouri, USA
  • LLM, International Trade Law (Dean’s gold medallist cum laude), University of the Western Cape, South Africa
  • LLB (Dean’s gold medallist), University of the Western Cape, South Africa

Admissions

  • Attorney of the Supreme Court of South Africa
  • Certified Mediator of the Supreme Court of Missouri, USA
  • Dubai Legal Affairs Department, UAE

Memberships

  • International Tax Specialists Group
  • International Fiscal Association (UAE)
Languages
  • Afrikaans
  • English
Insights