Raneem Alrakhaimi

Raneem Alrakhaimi

Tax Manager
About

Raneem is an all-round tax advisor with a focus on Saudi and international tax matters. She advises clients across the full spectrum of Saudi taxation, including corporate income tax, transfer pricing, value added tax and real estate taxation.

Raneem regularly advises multinational groups and regional market leaders in sectors aligned with the Kingdom’s strategic priorities, on structuring, operational tax considerations, and ongoing compliance.

Areas of FocusTax

EXPERIENCE

  • Advising a Latin American food and agribusiness on a multi-jurisdictional corporate restructuring across KSA, UAE, Qatar, Oman and Kuwait in a pre-IPO context, including the centralization of operations into a Saudi led structure and the redesign of operating and supply chain models to optimize indirect tax positions and cross border profit repatriation (including dividend withholding tax and participation exemption considerations).
  • Advising a leading Saudi AI and semiconductor ecosystem participant on asset focused cross border collaboration arrangements involving structured capital participation and profit linked returns.
  • Advising on the structuring of intra-group financing arrangements, the tax treatment and deductibility of interest on related-party debt, and the application of transfer pricing and anti-avoidance principles.
  • Supporting on a Mutual Agreement Procedure (MAP) cases under Saudi tax treaties, including disputes concerning PE profit attribution and the application of the force of attraction principles.
  • Reviewing and supporting transfer pricing documentation in KSA for both legal entities and permanent establishments, including strengthening and aligning profit attribution analyses in line with KSA and applicable international (OECD/ UN) standards.
  • Assisting MNEs in various sectors, including pharmaceuticals, technology, and financial services sectors in navigating Saudi RHQ requirements, including the treatment of “double hatter” employees and implementing practical safeguards to manage permanent establishment and broader cross-border tax risks.
  • Advising private investors on wealth structuring in the UAE using family foundations and partnership vehicles, with careful consideration of UAE domestic laws and applicable tax treaties.
Languages
  • English
  • Arabic
Education
  • MSc in Taxation, University of Oxford