Why the African Continental Free Trade Agreement has not yet turned into Reality — and What That Means for Egypt

26 February 2026

  • Egypt
  • Distribution
  • Foreign investments
  • Tax

Executive Summary

The African Continental Free Trade Area (AfCFTA) remains one of the most ambitious integration projects in the world. Yet, several years into its operational phase, it has not (yet) delivered the structural shift many expected. A recent analysis underscores the gap between political momentum and economic reality: implementation remains uneven, the agreement is still used by only a portion of participating states, and non-tariff barriers and infrastructure deficits continue to dominate the cost of doing business across borders.  For Egypt, the opportunity is still real — but it depends less on treaty headlines and more on enabling conditions: trade logistics, customs efficiency, regulatory convergence, and competitive industrial capacity. 

Looking Back: The Promise of a Single African Market

When the AfCFTA was launched, expectations were understandably high. A continent-wide trade framework was supposed to reduce tariffs, facilitate trade in goods and services, and strengthen regional value chains — with the broader goal of moving African economies up the value ladder.

In my 2022 article, I asked whether AfCFTA could become a game changer for Egypt, given Egypt’s industrial base, strategic geography, and the potential to diversify export markets beyond traditional partners. (For background, see the earlier article here”).

The Reality Check: Intra-African Trade Remains Structurally Weak

Several years later, the interim assessment is sobering. As the Frankfurter Allgemeine Zeitung (FAZ) recently put it, AfCFTA is not a “game changer” yet, and only about half of member states currently meet the practical prerequisites to trade under the agreement.

A deeper reason is structural: no other world region trades so little with itself, and while statistics may undercount informal cross-border flows (especially in food), the overall picture remains unchanged.

Trade integration cannot deliver transformative outcomes if production, logistics, and institutions do not support scale.

Implementation Has Been Slow — and Often Symbolic

Operationalisation did not start with full-scale liberalisation. Instead, the AfCFTA began with a pilot approach: the Guided Trade Initiative (GTI) launched in October 2022, initially with eight states, later joined by additional countries, including Nigeria and South Africa by spring 2025.

The GTI created valuable learning effects, but it also underlined a key point: early progress was often presented through symbolic deals, while product coverage and volumes remained limited. FAZ highlights that only selected goods could be traded duty-free and that key sectors remained constrained for a long time due to missing or unresolved technical rules.

A pilot, however, cannot substitute for full operational certainty — the kind businesses need to restructure supply chains and invest.

Tariffs Are Not the Main Barrier — Trade Costs Are

AfCFTA is frequently discussed in terms of tariff liberalisation. Yet, evidence suggests that the largest gains do not come from tariffs but from reducing non-tariff barriers and improving trade infrastructure.

FAZ points to a central reality: tariffs tend to add around 20–30% to intra-African trade costs, whereas non-tariff costs can be far higher — driven by bureaucracy, lack of harmonised standards, inefficient border processes, and transport barriers.

This is the crux: even with reduced tariffs, trade will not expand meaningfully if goods still cannot move cheaply, quickly, and predictably.

Integration Complexity and Distributional Politics

Africa’s integration landscape is shaped by multiple overlapping regional economic communities and trade regimes. This creates legal and administrative complexity — often described as an integration “spaghetti bowl.” FAZ notes the challenge of coordination and the continued fragmentation of rules.

There is also a political economy dimension. Intra-African trade is heavily influenced by a small number of larger economies — and the distribution of benefits matters. FAZ highlights the dominance of major players (notably South Africa) and the concern that tariff liberalisation alone may entrench existing industrial advantages.

Where governments expect asymmetric outcomes, resistance often takes the form of delay, narrow implementation, or persistent non-tariff barriers.

What This Means for Egypt: The Opportunity Is Real — But Conditional

Egypt’s strategic case for AfCFTA participation remains strong: industrial potential, geographic location, and the opportunity to access and shape growing markets. But the experience so far suggests that the treaty text alone does not generate trade flows.

For Egypt’s private sector, the decisive factors are practical:

  • predictable and efficient customs clearance and border procedures,
  • logistics corridors and port efficiency,
  • regulatory convergence (standards, certification, compliance),
  • stable access to trade finance and payments,
  • competitive energy and production conditions for manufacturing and processing.

AfCFTA can support these developments — but it cannot replace them.

The “Game Changer” Pathway: What Must Happen Next

FAZ concludes that AfCFTA will only become truly impactful if it is paired with the fundamentals: major infrastructure investment, stronger production and processing capacity, and a credible industrial policy.

At the same time, Africa faces a classic chicken-and-egg problem: without development there is limited investment appeal; without investment there is limited development.

For Egypt and its partners, a pragmatic strategy would be to:

  1. treat AfCFTA as a platform for real trade-cost reduction, not only tariff debates;
  2. focus on a limited number of scalable corridors and sectors where regional value chains can realistically grow;
  3. strengthen implementation capacity so that preferences become usable for firms — especially SMEs;
  4. enhance legal certainty and dispute resolution reliability for cross-border commerce.

Conclusion

AfCFTA remains a landmark achievement in terms of political commitment. But as of today, it has not yet been the “game changer” many hoped for.

For Egypt, the key question is no longer whether AfCFTA is visionary — it is. The question is whether governments and businesses can translate it into lower real trade costs, higher competitiveness, and bankable cross-border transactions. If those enabling conditions improve, AfCFTA’s promise can still become commercial reality.

Relocating to Spain for professional reasons is often an exciting step: a new career opportunity, a different lifestyle, and, in many cases, an improved quality of life. However, in practice, the most complex issues rarely arise from employment itself, but from the legal and tax implications surrounding housing.

Before signing a lease or purchasing a property, it is essential to understand your administrative and tax position in Spain. A proper legal assessment at the outset can prevent costly complications later.

Immigration Status: The Essential Starting Point

Not all foreign nationals are in the same legal position.

Citizens of the European Union may reside and work in Spain, but they must obtain a Foreigner Identification Number (NIE), register with the Central Register of Foreign Nationals, and register their address (empadronamiento) in the municipality where they reside.

Non-EU nationals, on the other hand, must first secure the appropriate visa or residence and work authorization, and subsequently obtain a Foreigner Identity Card (TIE).

This is not a mere administrative formality. Without a regularized status, practical issues may arise, including difficulties opening a bank account, setting up utilities, demonstrating financial solvency to landlords, or formalizing deeds before a notary.

Renting in Spain: What to Review Before Signing

Residential leases in Spain are governed by the Urban Leases Act (Ley de Arrendamientos Urbanos). Although legal residence is not technically required to sign a lease agreement, landlords often ask for additional guarantees if the tenant has recently arrived in the country.

It is important to review carefully:

  • The agreed duration of the lease
  • Rent update mechanisms
  • Security deposit and additional guarantees
  • Early termination clauses

Entering into a lease under time pressure, without fully understanding these terms, can result in financial obligations that may not align with the realities of an international relocation.

Purchasing Property: Legal Access and Tax Implications

Foreign nationals may freely acquire real estate in Spain, regardless of residency status. There are no nationality-based restrictions on ownership.

However, property acquisition has significant tax consequences that should be assessed in advance.

For resale properties, the Transfer Tax (Impuesto sobre Transmisiones Patrimoniales) applies, with rates varying depending on the Autonomous Community. For newly built properties, VAT (IVA) and Stamp Duty (Actos Jurídicos Documentados) are payable. Notarial and Land Registry fees must also be considered.

The transaction must be executed through a public deed before a Spanish notary and subsequently registered at the Land Registry to ensure full legal protection against third parties.

Tax Residency: A Determining Factor

One of the most critical issues is whether the relocating professional becomes a tax resident in Spain.

As a general rule, tax residence is acquired by spending more than 183 days in Spain during a calendar year or by having the primary center of economic interests located in Spain. This determination is based on objective criteria and is not dependent solely on municipal registration.

The distinction is substantial:

  • Spanish tax residents are taxed on their worldwide income.
  • Non-residents are taxed only on income obtained in Spain, under the Non-Resident Income Tax regime.

Even if a property is not rented, owners may be required to declare imputed income if it does not qualify as their primary residence.

Coordination with the Country of Origin

Relocating to Spain does not automatically eliminate tax obligations in the country of origin. Spain has signed numerous double taxation treaties, but their application requires case-by-case analysis.

Inadequate planning may lead to dual taxation, residency conflicts, or subsequent inquiries from tax authorities in either jurisdiction.

Plan Before You Commit

The correct sequence does not begin with signing a lease or reserving a property. It begins with

  • clarifying immigration status
  • defining tax residence, and
  • assessing the legal and financial implications of each decision.

Housing is not merely a real estate matter. It is a legal and economic commitment with medium- and long-term consequences.

When a professional move involves crossing borders, careful planning is not optional. It is a fundamental step in protecting both personal stability and the success of the new professional chapter.

New Regulatory Framework for RHQs: Tax Relief, Substantive Presence, and Streamlined Licensing

Saudi Arabia has released the long-awaited draft of the “Rules Regulating the Licensing and Supervision of Regional Headquarters of Multinational Companies,” issued pursuant to Cabinet Resolution No. (338) dated 23/4/1445H. This regulatory framework, currently open for public consultation, forms part of the Kingdom’s ambitious Vision 2030 strategy to establish Saudi Arabia as the prime regional base for multinational enterprises (MNEs) operating in the Middle East and North Africa (MENA) region.

Far beyond mere tax incentives, the draft Rules introduce a binding, structured regime that combines regulatory clarity with strict compliance obligations and long-term benefits. The most salient features include the following.

30-Year Tax Holiday

Entities licensed as RHQs will enjoy a 0% income tax rate and a 0% withholding tax rate on dividends, related-party payments, and payments for services essential to RHQ activity. These tax incentives are granted for a period of 30 years, renewable under conditions set by the Ministry of Investment.

Operational Substance Requirements: RHQ Functions and Compliance

At the core of the RHQ regime lies the requirement for substantial and sustained business presence in the Kingdom. Licensed RHQs must activate both mandatory and optional activities as defined in Article 7 of the Rules:

Mandatory Activities (to be activated within the first year):

  • Preparation and implementation of the regional strategy;
  • Strategic coordination of the MNE’s operations in the region;
  • Selection of products and services offered in the region;
  • M&A support;
  • Financial performance review;
  • Budget planning for regional operations;
  • Coordination of business units across MENA;
  • Market research and competitor analysis;
  • Identification of new market opportunities;
  • Marketing strategy development;
  • Preparation of operational and financial reports.

Optional Activities (minimum of three to be activated): These include, among others:

  • Research, development and innovation;
  • Sales and marketing;
  • Human resources and training;
  • Financial management, foreign exchange and treasury services;
  • Legal consultancy, compliance, internal audit;
  • Logistics, IP management, production, and technical support.

The selected optional activities must be aligned with the MNE’s global business strategy and must be regionally anchored.

Additional Substantive Requirements

  • Minimum of 15 employees in the first year;
  • At least 3 senior executives must be based in the Kingdom and must represent the top decision-making authority for the region;
  • RHQ staff must reside in Saudi Arabia, be dedicated full-time, be licensed locally, and receive remuneration through Saudi bank accounts;
  • RHQ operations must be exclusively performed within the Kingdom.

Licensing Process and Timing

The licensing process is clearly defined. Upon submission of the required documentation (commercial records, financials, activity plans), the Ministry of Investment will process the application within 30 working days.

True Regional Authority and Kingdom-Centric Operations

Licensed RHQs must hold administrative authority over all regional branches and subsidiaries. The RHQ must operate as the highest strategic, executive, and administrative authority in the MENA region. Furthermore, all RHQ-related activities must be carried out exclusively from within the Kingdom.

Localization Requirements

To ensure genuine local presence, the RHQ regime mandates:

  • Saudi residency and work permits for all RHQ personnel;
  • No hybrid or remote models from abroad;
  • Local registration of intellectual property and commercial identifiers;
  • Internal reporting and supervision obligations anchored in Saudi Arabia.

Is RHQ Establishment Mandatory or Optional?

While the RHQ license remains optional in principle, it is effectively mandatory for all multinational companies intending to contract with Saudi public sector entities.

As of 1 January 2024, the Saudi government will only consider public procurement contracts from companies that have an RHQ presence in the Kingdom, unless an express exemption is granted. Companies operating purely in the private sector without government contracts remain unaffected, but will nonetheless benefit from the RHQ regime if they choose to participate.

This regulatory shift creates a strategic filter: those seeking to participate in Saudi Arabia’s transformation across infrastructure, health, energy, and education must establish a fully embedded regional presence in the Kingdom.

Conclusion: High-Reward, High-Compliance Environment

The draft Rules represent a bold step in reshaping the MENA business landscape. Saudi Arabia is setting the bar high: generous tax relief and fast-track licensing are tied to substantive commitments in structure, personnel, and governance. For MNEs willing to assume regional leadership from within Saudi borders, the opportunity is as attractive as it is demanding.

A dedicated notary account in Brazil is a legal mechanism that brings greater security, transparency, and reliability to financial transactions. Regulated under Law 8.935/1994 and Provision No. 197/2025, this service allows notaries to receive, manage, and release funds only after contractual conditions have been fulfilled. By ensuring segregation of assets, traceability, and impartial oversight, dedicated notary accounts provide an effective escrow-like solution for real estate deals, mergers and acquisitions, import/export operations, high-value asset purchases, and complex commercial contracts. This tool not only reduces legal risks and potential disputes but also strengthens trust between parties by guaranteeing that payments are safeguarded until obligations are met.

The legal basis can be found in Law 8.935/1994, § 1 of art. 7-A, which allows notaries to receive, deposit, and manage amounts related to legal transactions, with transactions subject to objectively verifiable facts/conditions. Provision No. 197, dated June 13, 2025, regulates, at the national level, the service of notarial accounts linked to Notary Public Offices.

Practical applications: among others, in the following transactions:

  • Real estate: guarantee that the down payment and settlement amounts will be secured in a specific account. This mitigates the risk of misappropriation of funds and ensures that the money will be released only after all contractual conditions have been met.
  • M&A: the linked notarial account creates a standardized escrow mechanism for the payment of price/holdbacks/earn-outs and conditional obligations.
  • Purchase and Sale of High-Value Movable Property: the linked account can be used to guarantee payment. The buyer deposits the amount and the seller knows that the money is safe, being released only after the transfer of ownership and delivery of the goods.
  • Import and Export: the transaction amount can be deposited with the notary and released to the exporter only after confirmation of delivery of the goods in the destination country, for example.
  • Guarantee of Obligations: In any contract that provides for the payment of a sum of money as a guarantee, the notary account can be used to provide greater security to the parties.
  • Supply, EPC/turnkey, and construction contracts: performance retentions, milestone acceptance (commissioning, as-built, issuance of ART/CREA), and payment against formal acceptance.
  • Contractual joint ventures and commercial partnerships: advances conditional on licenses, authorizations, or competitive approval, where applicable.

Reduction of Legal Risks: The use of linked accounts reduces the chances of litigation related to lack of clarity about the origin and destination of funds. Companies can clearly demonstrate that payments were made and held by an impartial and secure institution.

Operational structure: limited to banking entities affiliated with the CNB, which must ensure the segregation of assets, traceability through audit trails, and proof of all transactions. The authorization of the delegate requires prior accreditation and electronic registration of the essential details of the transaction and its conditions in the CNB system, with access restricted to the parties and the notary.

Specific Purpose: amounts received as payment, guarantee, or advance payment as a result of notarial acts must be deposited in a bank account linked to the specific act and may only be moved for the purpose for which they are intended.

Transparency and Traceability: With the linked notarial account, it is possible to clearly track the financial flow of each transaction, which increases transparency for all parties and for supervisory bodies.

Verification of conditions and release. Once the objective conditions have been met, the notary authorizes the transfer to the recipients and files the proof of verification. In the event of a dispute between the parties, the notary suspends any movement, draws up a notarial deed, and advises on a consensual or judicial solution, without deciding on the effectiveness/termination of the transaction; if the transaction is frustrated and no solution is found, the procedure is terminated and the amounts are returned to the depositor, in accordance with the agreed clauses.

Confidentiality and access. In transactions with a confidentiality clause, the notary public maintains confidentiality and does not issue certificates regarding the content of the transaction; documents are accessible only for correctional purposes or by court order.

Remuneration and costs. The notary’s remuneration for the notarial account service is paid by the financial institution under the terms of the agreement, and the transfer of additional costs to the user is prohibited, without prejudice to fees for any related notarial acts.

The Government of Vietnam has issued a new decree governing internet services and online information, which shall come into force on 25 December 2024. Decree No. 147/2024/ND-CP, promulgated on 9 November 2024, supersedes the previous Decree No. 72/2013/ND-CP and its amendments.

This comprehensive legislation, comprising over 200 pages and 62 appended forms, addresses a wide array of internet and online topics. These include inter alia, internet services, domain names, cross-border information provision, social network services, aggregated information websites, online game services, and app store services.

Key Provisions

Cross-Border Information Provision

Offshore service providers, including those offering social network and app store services on a cross-border basis, are subject to stricter requirements if they either lease data storage in Vietnam or meet a threshold of 100,000 or more total visits per month from Vietnam for six consecutive months. These providers must:

  1. Notify the Authority of Broadcasting and Electronic Information (ABEI) of their contact information
  2. Monitor and remove illegal content
  3. Store and manage user data as required
  4. Authenticate social network user accounts using Vietnamese mobile numbers or identification numbers
  5. Submit annual and ad hoc reports to the ABEI
  6. Handle user complaints

Only cross-border providers who have notified the ABEI of their contact details may offer live stream and revenue-generating services. Non-compliance may result in blocks and penalties.

Social Networks

Decree 147 establishes distinct regimes for offshore and onshore social network services:

  1. Offshore providers meeting the aforementioned threshold must notify the ABEI of their contact information.
  2. Onshore providers reaching 10,000 total visits per month for six consecutive months or 1,000 regular users per month must obtain a Social Network Licence.
  3. Other onshore providers with low traffic must obtain a Notification Certificate from the ABEI.

The decree also regulates livestream activities by stipulating conditions for social network service providers to offer livestream functions and for social network accounts to conduct livestream activities.

Online Games

Foreign organisations and individuals are prohibited from providing online games to service users in Vietnam on a cross-border basis. To offer such services, they must establish a local enterprise in Vietnam.

This new decree is expected to have a significant impact on both onshore and offshore service providers in the respective fields and may tighten the regulatory landscape for internet services and online information provision in Vietnam.

“This agreement is not just an economic opportunity. It is a political necessity.” In the current geopolitical context of growing protectionism and significant regional conflicts, Ursula von der Leyen’s statement says a lot.

Even though there is still a long way to go before the agreement is approved internally in each bloc and comes into force, the milestone is highly significant. It took 25 years from the start of negotiations between Mercosur and the European Union to reach a consensus text. The impacts will be considerable. Together, the blocs represent a GDP of over 22 trillion dollars, and are home to over 700 million people.

Our aim here is to highlight, in a simplified manner, the most important information about the agreement’s content and its progress, which we will update here at each stage.

What is it?

The agreement was signed as a trade treaty, with the main goal of reducing import and export tariffs, eliminating bureaucratic barriers, and facilitating trade between Mercosur countries and European Union members. Additionally, the pact includes commitments in areas such as sustainability, labor rights, technological cooperation, and environmental protection.

Mercosur (Southern Common Market) is an economic bloc created in 1991 by Brazil, Argentina, Paraguay, and Uruguay. Now, Bolivia and Chile participate as associated members, accessing some trade agreements, but not fully integrated into the common market. On the other hand, the European Union, with its 27 members (20 of which have adopted the common currency), is a broader union with greater economic and social integration compared to Mercosur.

What does the EU Mercosur agreement include?

Trade in goods:

  • Reduction or elimination of tariffs on products traded between the blocs, such as meat, grains, fruits, automobiles, wines, and dairy products (the expected reduction will affect over 90% of the traded goods between the blocks).
  • Easier access to European high-tech and industrialized products.

Trade in services:

  • Expands access to financial services, telecommunications, transportation, and consulting for businesses in both blocs.

Movement of people:

  • Provides facilities for temporary visas for qualified workers, such as technology professionals and engineers, promoting talent exchange.
  • Encourages educational and cultural cooperation programs.

Sustainability and environment:

  • Includes commitments to combat deforestation and meet the goals of the Paris Agreement on climate change.
  • Provides penalties for violations of environmental standards.

Intellectual property and regulations:

  • Protects geographical indications for European cheese, wines, and South American coffee and cachaça.
  • Harmonizes regulatory standards to reduce bureaucracy and avoid technical barriers.

Labor rights:

  • Commitment to decent working conditions and compliance with International Labor Organization (ILO) standards.

Which benefits to expect?

  • Access to new markets: Mercosur companies will have easier access to the European market, which has more than 450 million consumers, while European products will become more competitive in South America.
  • Costs reduction: The elimination or reduction of tariffs could lower the prices of products such as wines, cheese, and automobiles and boost South American exports of meat, grains, and fruits.
  • Strengthened diplomatic relations: The agreement symbolizes a bridge of cooperation between two regions historically connected by cultural and economic ties.

What’s next?

The signing is only the first step. For the agreement to come into force, it must be ratified by both blocs, and the approval process is quite distinct between them, since Mercosur does not have a common Council or Parliament.

In the European Union, the ratification process involves multiple institutional steps:

  • Council of the European Union: Ministers from the member states will discuss and approve the text of the agreement. This step is crucial, as each country has representation and may raise specific national concerns.
  • European Parliament: After approval by the Council, the European Parliament, composed of elected deputies, votes to ratify the agreement. The debate at this stage may include environmental, social, and economic impacts.
  • National Parliaments: In cases where the agreement affects shared competencies between the bloc and member states (such as environmental regulations), it must also be approved by the parliaments of each member country. This can be challenging, given that countries like France and Ireland have already expressed specific concerns about agricultural and environmental issues.

In Mercosur, the approval depends on each member country:

  • National Congresses: The agreement text is submitted to the parliaments of Brazil, Argentina, Paraguay, and Uruguay. Each congress evaluates independently, and approval depends on the political majority in each country.
  • Political Context: Mercosur countries have diverse political realities. In Brazil, for example, environmental issues can spark heated debates, while in Argentina, the impact on agricultural competitiveness may be the focus of discussion.
  • Regional Coordination: Even after national approval, it is necessary to ensure that all Mercosur members ratify the agreement, as the bloc acts as a single negotiating entity.

Stay tuned: you will find the update here as the processes advance.

Vietnam has embraced the global minimum tax (GMT) to harmonize its tax policies with global standards. While this new tax regime is anticipated to have certain adverse effects on foreign direct investment (FDI), the Vietnamese government is devising proactive measures to mitigate these repercussions and maintain the country’s appeal as an investment haven.

Key Ramifications of the GMT for Vietnam

The GMT mandates multinational corporations (MNCs) with consolidated revenue surpassing €750 million to pay a minimum tax rate of 15%, irrespective of the tax rate in the country where they operate. In Vietnam, this translates to the concept of a qualified domestic minimum top-up tax (QDMTT).

The QDMTT places an extra tax burden on foreign-invested enterprises (FIEs) that are part of an MNC, potentially deterring them from investing or expanding in Vietnam. This is particularly concerning for industries that heavily rely on tax incentives to attract FDI.

Vietnam’s Response: Investment Support Fund and Proactive Measures

In response to the anticipated negative impacts of the GMT, the Vietnamese government has established an investment support fund (Fund) to incentivize investments in targeted sectors. The Fund is primarily funded by proceeds from the State Budget generated by the GMT.

Eligible enterprises for the Fund are those engaged in high-tech product manufacturing, high-tech enterprises, high-tech application projects, and enterprises with investment projects in research and development centers. Eligibility is based on capital size, annual revenue, industry, or technology utilized.

Eligible taxpayers can receive cash subsidies for five specific expense categories:

  1. Human resource training and development
  2. Research and development expenses
  3. Fixed asset investments
  4. High-tech manufacturing expenses
  5. Social infrastructure systems

To qualify for Fund benefits, eligible taxpayers must submit an application dossier to the Fund Office in Hanoi between August 15th and 30th of the year following the incurred Supported Expenses. Each Supported Expense category will have a distinct reimbursement ratio, and support payments will be contingent on the actual expenses incurred by eligible taxpayers.

In addition to the Fund, the Vietnamese government is also implementing proactive measures to address the concerns of foreign investors. These measures include:

  1. Focusing on targeted industries with high growth potential that align with Vietnam’s strategic development goals
  2. Utilizing the additional revenue collected from top-up tax to enhance infrastructure and labor quality
  3. Considering cash grants for long-term qualified investments in high-tech industries

Conclusion

The introduction of the GMT poses challenges for Vietnam in attracting FDI. However, the government’s establishment of the investment support fund and proactive measures demonstrates its commitment to safeguarding the country’s competitiveness as an investment destination. By combining targeted support with infrastructure improvements and incentives for specific industries, Vietnam can mitigate the negative impacts of the GMT and continue to attract foreign investors.

Summary

Egypt aims to be Africa’s first green hydrogen producer by incentivizing companies to invest in the sector. Collaborative efforts with Germany and European companies are underway to enhance hydrogen projects and transport. Incentives include financial subsidies, tax exemptions, and administrative advantages, contingent on project conditions like commissioning, foreign funding, local materials use, and community development.

What is the status of green energy in Egypt and what role does green hydrogen play in this?

It is currently estimated that Egypt has the potential to generate 350 GW of wind energy and about 650 GW of solar energy per year, as per the Minister of Electricity and Renewable Energy’s (Mohamed Shaker El-Marqabi) declaration. As part of its National Climate Strategy 2050, Egypt has set itself the goal of reducing its carbon emissions, promoting the use of renewable energy sources and using alternative forms of energy, including green hydrogen. The importance the Egyptian government attaches to green hydrogen is evident, not least with the recent cabinet meeting on 17th of May 2023.

With a view to becoming the first African country to produce green hydrogen, new incentives for green hydrogen and derivatives projects were presented at the cabinet meeting. Based on an investment of 13 billion USD, the legal and financial benefits (new incentive package) that companies in this field can benefit from in the future were presented.

What agreements exist between Egypt and third countries to promote green hydrogen?

Agreement between Egypt and Germany on green hydrogen

The new incentive package was preceded by a meeting between the German-Egyptian Partnership for Green Hydrogen Projects committee and Egyptian officials on the 14th of March 2023. This resulted in a joint roadmap for supporting hydrogen production companies and promoting hydrogen transport and marketing. At this meeting, it was decided that the parties, the Egyptian Minister of International Cooperation (Rania Al-Mashat) and the Egyptian Minister of Public Enterprises (Mahmoud Esmat), will establish a platform to promote the use of green hydrogen.

At the above-mentioned meeting, Egypt and Germany signed two Memoranda of Understanding (MoU) to enhance cooperation in the field of green hydrogen.

The Egyptian Government also recently signed other MoUs with seven European leading companies and global alliances to produce new and renewable energy, to establish green hydrogen production complexes in Ain Al-Sokhna and the Red Sea Governorate.

The German-Egyptian cooperation in the field of green hydrogen follows Egypt’s goal to establish itself as a hub for producing green hydrogen.

Agreement between Egypt and third countries on green hydrogen

Egypt has also partnered with the European Union to advance green hydrogen production. Furthermore, in 2022, on the occasion of COP27, Egypt signed a series of MoUs with several international organisations to engage foreign investment in green hydrogen production and make Egypt a transit route for clean energy to Europe.

MoUs with global companies and alliances have defined the Red Sea Governorate as the location where green hydrogen projects will be carried out in the future.

Are there investment incentives for the production of green hydrogen in Egypt?

In the cabinet meeting of 17th of May 2023, the Egyptian Prime Minister Mustafa Madbuli stated that Egypt was offering the “largest” package of investment incentives and facilitations to companies wishing to invest in green hydrogen production projects in Egypt. He further announced the formation of a working group composed of representatives of the authorities involved to elaborate these investment incentives.

The statement indicated that companies involved in green energy projects in Egypt will benefit from incentives set out in the Law drafted in the cabinet meeting of 17th of May 2023 and Investment Law No. 72 of 2017. This targets companies involved in the “production, storage and export of green hydrogen”.

What investment incentives for the production of green hydrogen in Egypt are provided for in the draft Law of 17th of May 2023?

Financial incentives

Investments in the green hydrogen sector are subsidised in the amount of 33 % to 55 % of the income tax payable. The Ministry of Finance pays the subsidy within 45 days after the deadline for filing the tax return. The subsidy itself is not taxable. The exact conditions for the payment of the subsidy are still to be determined by the Cabinet.

All machinery, equipment, materials, consumables and vehicles (except private vehicles) used in green hydrogen and derivative projects are exempt from VAT.

No VAT is levied on exports of green hydrogen and its derivatives.

The Ministry of Finance pays most of the duties and certification costs associated with setting up the business and all import duties on imported goods used by the establishment. Further, it pays the taxes that would have been levied on the real estate used for the activity, if any.

Administrative incentives

Projects in the field of green hydrogen or its derivatives benefit from the so-called golden licence, as it is called in the Investment Law No. 72 of 2017.

All raw materials, spare parts and vehicles required for operations can be freely imported or exported directly or through distributors without the need for registration in the Importers’ Register.

The incentives apply to projects and their extensions throughout the contract period if the project agreements are concluded within a maximum of 7 years from the date of commercial commissioning.

Requirements

The investment incentives apply when:

  • the project is commissioned within 5 years of the signing of the project agreement
  • at least 70 % of the investment costs come from foreign funds
  • at least 20 % of the locally used materials originate from Egypt
  • training programmes are set up for local workers and know-how is shared
  • the project company draws up a development plan for the communities in which it will operate

What investment incentives for the production of green hydrogen in Egypt are provided for in the Investment Law No. 72 of 2017?

The tax incentives granted under the Investment Law No. 72 of 2017 provide for special, general and additional incentives.

Special incentives

These are tax reductions limited to 7 years for projects that are started within 3 years (extendable to 6 years) after the provisions of the Law No. 72 of 2017 came into force (i.e. by October 2023). The investment costs consist of equity capital, long-term loans to finance the construction of the project’s movable and immovable assets, and working capital. The tax base is the taxable net profit, which is taxed at the following rates:

1) Tax exemption on 50 % of the investment costs for the implementation of a project in geographical locations with the greatest development needs (underdeveloped locations) designated by the Central Agency for Public Mobilization and Statistics (CAPMS)

The law identifies these sites as “Zone A”. According to the implementing regulations, “Zone A” includes:

  • the Suez Canal Economic Zone
  • the Golden Triangle Special Economic Zone
  • the New Administrative Capital Zone
  • the south of Giza province
  • the provinces of Port Said, Ismailia and Suez (east of the canal) connected to the Suez Canal.
  • border provinces, including Red Sea province south of Safaga
  • the provinces in upper Egypt
  • other areas in greatest need of development (to be determined by the Prime Minister)

2) Tax exemption on 30 % of the investment costs of a project located in the remaining geographical areas outside “Zone A”, referred to as “Zone B”, and operating in certain sectors.

This includes projects that:

  • are active in the field of renewable energies
  • export their products outside Egypt
  • be carried out by a small or medium-sized (SME)

General incentives

Parallel to the special investment incentives, general investment incentives also apply. For example, projects are exempt from certain administrative requirements and fees for a period of 5 years from the date of their registration in the commercial register. Furthermore, temporary duty-free imports and exports are possible.

Additional incentives

Additional investment incentives may also be granted by decision of the Council of Ministers:

  • special customs offices for the export or import of the investment project
  • bearing of the value of the utility supply (such as electricity and water supply) of the property intended for the investment project or part thereof by the State
  • partial bearing of the costs of a technical training programme for employees by the State
  • reimbursement of half of the value of the land allocated for industrial projects, provided that the activity was started within two years of the transfer of the land
  • free allocation of land for certain strategic activities
  • under certain conditions, granting of a general permit for the construction, operation and management of the project as well as for the provision of the land required for this purpose. This permit shall also be deemed to be a building permit and shall be effective in its own right without any further action being required. In December 2022, the Egyptian Cabinet granted general approval for several projects.
  • incorporation shares of capital companies subject to the Investment Law No. 72 of 2017 may be traded during the first two fiscal years of the company, subject to the approval of the competent Minister
  • simplified acquisition of real estate, provided it is used for the project

Takeaways

  • Egypt’s Green Hydrogen Drive: Egypt is strategically embracing green hydrogen production as a pivotal element of its renewable energy vision. The country’s ambitious goals and extensive incentives underscore its commitment to becoming a leading player in the global green energy landscape.
  • International Collaborations: Collaborations with Germany and European partners highlight Egypt’s proactive approach to international cooperation in advancing green hydrogen technologies. Memoranda of Understanding and joint roadmaps are facilitating knowledge exchange and investments for robust hydrogen projects.
  • Comprehensive Incentive Framework: Egypt’s multifaceted incentive framework, including financial subsidies, tax exemptions, and administrative benefits, showcases the government’s determination to attract investments in green hydrogen production. Stringent conditions for benefiting from these incentives emphasize the nation’s dedication to sustainable practices and local community development.

Christian Ule

Practice areas

  • Arbitration
  • Contracts
  • Corporate
  • Distribution
  • International trade
Contact Christian

Contact Christian





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    Moving to Spain for Work | Legal and Tax Considerations Before Renting or Buying Property

    26 February 2026

    • Spain
    • Foreign investments
    • Real Estate

    Executive Summary

    The African Continental Free Trade Area (AfCFTA) remains one of the most ambitious integration projects in the world. Yet, several years into its operational phase, it has not (yet) delivered the structural shift many expected. A recent analysis underscores the gap between political momentum and economic reality: implementation remains uneven, the agreement is still used by only a portion of participating states, and non-tariff barriers and infrastructure deficits continue to dominate the cost of doing business across borders.  For Egypt, the opportunity is still real — but it depends less on treaty headlines and more on enabling conditions: trade logistics, customs efficiency, regulatory convergence, and competitive industrial capacity. 

    Looking Back: The Promise of a Single African Market

    When the AfCFTA was launched, expectations were understandably high. A continent-wide trade framework was supposed to reduce tariffs, facilitate trade in goods and services, and strengthen regional value chains — with the broader goal of moving African economies up the value ladder.

    In my 2022 article, I asked whether AfCFTA could become a game changer for Egypt, given Egypt’s industrial base, strategic geography, and the potential to diversify export markets beyond traditional partners. (For background, see the earlier article here”).

    The Reality Check: Intra-African Trade Remains Structurally Weak

    Several years later, the interim assessment is sobering. As the Frankfurter Allgemeine Zeitung (FAZ) recently put it, AfCFTA is not a “game changer” yet, and only about half of member states currently meet the practical prerequisites to trade under the agreement.

    A deeper reason is structural: no other world region trades so little with itself, and while statistics may undercount informal cross-border flows (especially in food), the overall picture remains unchanged.

    Trade integration cannot deliver transformative outcomes if production, logistics, and institutions do not support scale.

    Implementation Has Been Slow — and Often Symbolic

    Operationalisation did not start with full-scale liberalisation. Instead, the AfCFTA began with a pilot approach: the Guided Trade Initiative (GTI) launched in October 2022, initially with eight states, later joined by additional countries, including Nigeria and South Africa by spring 2025.

    The GTI created valuable learning effects, but it also underlined a key point: early progress was often presented through symbolic deals, while product coverage and volumes remained limited. FAZ highlights that only selected goods could be traded duty-free and that key sectors remained constrained for a long time due to missing or unresolved technical rules.

    A pilot, however, cannot substitute for full operational certainty — the kind businesses need to restructure supply chains and invest.

    Tariffs Are Not the Main Barrier — Trade Costs Are

    AfCFTA is frequently discussed in terms of tariff liberalisation. Yet, evidence suggests that the largest gains do not come from tariffs but from reducing non-tariff barriers and improving trade infrastructure.

    FAZ points to a central reality: tariffs tend to add around 20–30% to intra-African trade costs, whereas non-tariff costs can be far higher — driven by bureaucracy, lack of harmonised standards, inefficient border processes, and transport barriers.

    This is the crux: even with reduced tariffs, trade will not expand meaningfully if goods still cannot move cheaply, quickly, and predictably.

    Integration Complexity and Distributional Politics

    Africa’s integration landscape is shaped by multiple overlapping regional economic communities and trade regimes. This creates legal and administrative complexity — often described as an integration “spaghetti bowl.” FAZ notes the challenge of coordination and the continued fragmentation of rules.

    There is also a political economy dimension. Intra-African trade is heavily influenced by a small number of larger economies — and the distribution of benefits matters. FAZ highlights the dominance of major players (notably South Africa) and the concern that tariff liberalisation alone may entrench existing industrial advantages.

    Where governments expect asymmetric outcomes, resistance often takes the form of delay, narrow implementation, or persistent non-tariff barriers.

    What This Means for Egypt: The Opportunity Is Real — But Conditional

    Egypt’s strategic case for AfCFTA participation remains strong: industrial potential, geographic location, and the opportunity to access and shape growing markets. But the experience so far suggests that the treaty text alone does not generate trade flows.

    For Egypt’s private sector, the decisive factors are practical:

    • predictable and efficient customs clearance and border procedures,
    • logistics corridors and port efficiency,
    • regulatory convergence (standards, certification, compliance),
    • stable access to trade finance and payments,
    • competitive energy and production conditions for manufacturing and processing.

    AfCFTA can support these developments — but it cannot replace them.

    The “Game Changer” Pathway: What Must Happen Next

    FAZ concludes that AfCFTA will only become truly impactful if it is paired with the fundamentals: major infrastructure investment, stronger production and processing capacity, and a credible industrial policy.

    At the same time, Africa faces a classic chicken-and-egg problem: without development there is limited investment appeal; without investment there is limited development.

    For Egypt and its partners, a pragmatic strategy would be to:

    1. treat AfCFTA as a platform for real trade-cost reduction, not only tariff debates;
    2. focus on a limited number of scalable corridors and sectors where regional value chains can realistically grow;
    3. strengthen implementation capacity so that preferences become usable for firms — especially SMEs;
    4. enhance legal certainty and dispute resolution reliability for cross-border commerce.

    Conclusion

    AfCFTA remains a landmark achievement in terms of political commitment. But as of today, it has not yet been the “game changer” many hoped for.

    For Egypt, the key question is no longer whether AfCFTA is visionary — it is. The question is whether governments and businesses can translate it into lower real trade costs, higher competitiveness, and bankable cross-border transactions. If those enabling conditions improve, AfCFTA’s promise can still become commercial reality.

    Relocating to Spain for professional reasons is often an exciting step: a new career opportunity, a different lifestyle, and, in many cases, an improved quality of life. However, in practice, the most complex issues rarely arise from employment itself, but from the legal and tax implications surrounding housing.

    Before signing a lease or purchasing a property, it is essential to understand your administrative and tax position in Spain. A proper legal assessment at the outset can prevent costly complications later.

    Immigration Status: The Essential Starting Point

    Not all foreign nationals are in the same legal position.

    Citizens of the European Union may reside and work in Spain, but they must obtain a Foreigner Identification Number (NIE), register with the Central Register of Foreign Nationals, and register their address (empadronamiento) in the municipality where they reside.

    Non-EU nationals, on the other hand, must first secure the appropriate visa or residence and work authorization, and subsequently obtain a Foreigner Identity Card (TIE).

    This is not a mere administrative formality. Without a regularized status, practical issues may arise, including difficulties opening a bank account, setting up utilities, demonstrating financial solvency to landlords, or formalizing deeds before a notary.

    Renting in Spain: What to Review Before Signing

    Residential leases in Spain are governed by the Urban Leases Act (Ley de Arrendamientos Urbanos). Although legal residence is not technically required to sign a lease agreement, landlords often ask for additional guarantees if the tenant has recently arrived in the country.

    It is important to review carefully:

    • The agreed duration of the lease
    • Rent update mechanisms
    • Security deposit and additional guarantees
    • Early termination clauses

    Entering into a lease under time pressure, without fully understanding these terms, can result in financial obligations that may not align with the realities of an international relocation.

    Purchasing Property: Legal Access and Tax Implications

    Foreign nationals may freely acquire real estate in Spain, regardless of residency status. There are no nationality-based restrictions on ownership.

    However, property acquisition has significant tax consequences that should be assessed in advance.

    For resale properties, the Transfer Tax (Impuesto sobre Transmisiones Patrimoniales) applies, with rates varying depending on the Autonomous Community. For newly built properties, VAT (IVA) and Stamp Duty (Actos Jurídicos Documentados) are payable. Notarial and Land Registry fees must also be considered.

    The transaction must be executed through a public deed before a Spanish notary and subsequently registered at the Land Registry to ensure full legal protection against third parties.

    Tax Residency: A Determining Factor

    One of the most critical issues is whether the relocating professional becomes a tax resident in Spain.

    As a general rule, tax residence is acquired by spending more than 183 days in Spain during a calendar year or by having the primary center of economic interests located in Spain. This determination is based on objective criteria and is not dependent solely on municipal registration.

    The distinction is substantial:

    • Spanish tax residents are taxed on their worldwide income.
    • Non-residents are taxed only on income obtained in Spain, under the Non-Resident Income Tax regime.

    Even if a property is not rented, owners may be required to declare imputed income if it does not qualify as their primary residence.

    Coordination with the Country of Origin

    Relocating to Spain does not automatically eliminate tax obligations in the country of origin. Spain has signed numerous double taxation treaties, but their application requires case-by-case analysis.

    Inadequate planning may lead to dual taxation, residency conflicts, or subsequent inquiries from tax authorities in either jurisdiction.

    Plan Before You Commit

    The correct sequence does not begin with signing a lease or reserving a property. It begins with

    • clarifying immigration status
    • defining tax residence, and
    • assessing the legal and financial implications of each decision.

    Housing is not merely a real estate matter. It is a legal and economic commitment with medium- and long-term consequences.

    When a professional move involves crossing borders, careful planning is not optional. It is a fundamental step in protecting both personal stability and the success of the new professional chapter.

    New Regulatory Framework for RHQs: Tax Relief, Substantive Presence, and Streamlined Licensing

    Saudi Arabia has released the long-awaited draft of the “Rules Regulating the Licensing and Supervision of Regional Headquarters of Multinational Companies,” issued pursuant to Cabinet Resolution No. (338) dated 23/4/1445H. This regulatory framework, currently open for public consultation, forms part of the Kingdom’s ambitious Vision 2030 strategy to establish Saudi Arabia as the prime regional base for multinational enterprises (MNEs) operating in the Middle East and North Africa (MENA) region.

    Far beyond mere tax incentives, the draft Rules introduce a binding, structured regime that combines regulatory clarity with strict compliance obligations and long-term benefits. The most salient features include the following.

    30-Year Tax Holiday

    Entities licensed as RHQs will enjoy a 0% income tax rate and a 0% withholding tax rate on dividends, related-party payments, and payments for services essential to RHQ activity. These tax incentives are granted for a period of 30 years, renewable under conditions set by the Ministry of Investment.

    Operational Substance Requirements: RHQ Functions and Compliance

    At the core of the RHQ regime lies the requirement for substantial and sustained business presence in the Kingdom. Licensed RHQs must activate both mandatory and optional activities as defined in Article 7 of the Rules:

    Mandatory Activities (to be activated within the first year):

    • Preparation and implementation of the regional strategy;
    • Strategic coordination of the MNE’s operations in the region;
    • Selection of products and services offered in the region;
    • M&A support;
    • Financial performance review;
    • Budget planning for regional operations;
    • Coordination of business units across MENA;
    • Market research and competitor analysis;
    • Identification of new market opportunities;
    • Marketing strategy development;
    • Preparation of operational and financial reports.

    Optional Activities (minimum of three to be activated): These include, among others:

    • Research, development and innovation;
    • Sales and marketing;
    • Human resources and training;
    • Financial management, foreign exchange and treasury services;
    • Legal consultancy, compliance, internal audit;
    • Logistics, IP management, production, and technical support.

    The selected optional activities must be aligned with the MNE’s global business strategy and must be regionally anchored.

    Additional Substantive Requirements

    • Minimum of 15 employees in the first year;
    • At least 3 senior executives must be based in the Kingdom and must represent the top decision-making authority for the region;
    • RHQ staff must reside in Saudi Arabia, be dedicated full-time, be licensed locally, and receive remuneration through Saudi bank accounts;
    • RHQ operations must be exclusively performed within the Kingdom.

    Licensing Process and Timing

    The licensing process is clearly defined. Upon submission of the required documentation (commercial records, financials, activity plans), the Ministry of Investment will process the application within 30 working days.

    True Regional Authority and Kingdom-Centric Operations

    Licensed RHQs must hold administrative authority over all regional branches and subsidiaries. The RHQ must operate as the highest strategic, executive, and administrative authority in the MENA region. Furthermore, all RHQ-related activities must be carried out exclusively from within the Kingdom.

    Localization Requirements

    To ensure genuine local presence, the RHQ regime mandates:

    • Saudi residency and work permits for all RHQ personnel;
    • No hybrid or remote models from abroad;
    • Local registration of intellectual property and commercial identifiers;
    • Internal reporting and supervision obligations anchored in Saudi Arabia.

    Is RHQ Establishment Mandatory or Optional?

    While the RHQ license remains optional in principle, it is effectively mandatory for all multinational companies intending to contract with Saudi public sector entities.

    As of 1 January 2024, the Saudi government will only consider public procurement contracts from companies that have an RHQ presence in the Kingdom, unless an express exemption is granted. Companies operating purely in the private sector without government contracts remain unaffected, but will nonetheless benefit from the RHQ regime if they choose to participate.

    This regulatory shift creates a strategic filter: those seeking to participate in Saudi Arabia’s transformation across infrastructure, health, energy, and education must establish a fully embedded regional presence in the Kingdom.

    Conclusion: High-Reward, High-Compliance Environment

    The draft Rules represent a bold step in reshaping the MENA business landscape. Saudi Arabia is setting the bar high: generous tax relief and fast-track licensing are tied to substantive commitments in structure, personnel, and governance. For MNEs willing to assume regional leadership from within Saudi borders, the opportunity is as attractive as it is demanding.

    A dedicated notary account in Brazil is a legal mechanism that brings greater security, transparency, and reliability to financial transactions. Regulated under Law 8.935/1994 and Provision No. 197/2025, this service allows notaries to receive, manage, and release funds only after contractual conditions have been fulfilled. By ensuring segregation of assets, traceability, and impartial oversight, dedicated notary accounts provide an effective escrow-like solution for real estate deals, mergers and acquisitions, import/export operations, high-value asset purchases, and complex commercial contracts. This tool not only reduces legal risks and potential disputes but also strengthens trust between parties by guaranteeing that payments are safeguarded until obligations are met.

    The legal basis can be found in Law 8.935/1994, § 1 of art. 7-A, which allows notaries to receive, deposit, and manage amounts related to legal transactions, with transactions subject to objectively verifiable facts/conditions. Provision No. 197, dated June 13, 2025, regulates, at the national level, the service of notarial accounts linked to Notary Public Offices.

    Practical applications: among others, in the following transactions:

    • Real estate: guarantee that the down payment and settlement amounts will be secured in a specific account. This mitigates the risk of misappropriation of funds and ensures that the money will be released only after all contractual conditions have been met.
    • M&A: the linked notarial account creates a standardized escrow mechanism for the payment of price/holdbacks/earn-outs and conditional obligations.
    • Purchase and Sale of High-Value Movable Property: the linked account can be used to guarantee payment. The buyer deposits the amount and the seller knows that the money is safe, being released only after the transfer of ownership and delivery of the goods.
    • Import and Export: the transaction amount can be deposited with the notary and released to the exporter only after confirmation of delivery of the goods in the destination country, for example.
    • Guarantee of Obligations: In any contract that provides for the payment of a sum of money as a guarantee, the notary account can be used to provide greater security to the parties.
    • Supply, EPC/turnkey, and construction contracts: performance retentions, milestone acceptance (commissioning, as-built, issuance of ART/CREA), and payment against formal acceptance.
    • Contractual joint ventures and commercial partnerships: advances conditional on licenses, authorizations, or competitive approval, where applicable.

    Reduction of Legal Risks: The use of linked accounts reduces the chances of litigation related to lack of clarity about the origin and destination of funds. Companies can clearly demonstrate that payments were made and held by an impartial and secure institution.

    Operational structure: limited to banking entities affiliated with the CNB, which must ensure the segregation of assets, traceability through audit trails, and proof of all transactions. The authorization of the delegate requires prior accreditation and electronic registration of the essential details of the transaction and its conditions in the CNB system, with access restricted to the parties and the notary.

    Specific Purpose: amounts received as payment, guarantee, or advance payment as a result of notarial acts must be deposited in a bank account linked to the specific act and may only be moved for the purpose for which they are intended.

    Transparency and Traceability: With the linked notarial account, it is possible to clearly track the financial flow of each transaction, which increases transparency for all parties and for supervisory bodies.

    Verification of conditions and release. Once the objective conditions have been met, the notary authorizes the transfer to the recipients and files the proof of verification. In the event of a dispute between the parties, the notary suspends any movement, draws up a notarial deed, and advises on a consensual or judicial solution, without deciding on the effectiveness/termination of the transaction; if the transaction is frustrated and no solution is found, the procedure is terminated and the amounts are returned to the depositor, in accordance with the agreed clauses.

    Confidentiality and access. In transactions with a confidentiality clause, the notary public maintains confidentiality and does not issue certificates regarding the content of the transaction; documents are accessible only for correctional purposes or by court order.

    Remuneration and costs. The notary’s remuneration for the notarial account service is paid by the financial institution under the terms of the agreement, and the transfer of additional costs to the user is prohibited, without prejudice to fees for any related notarial acts.

    The Government of Vietnam has issued a new decree governing internet services and online information, which shall come into force on 25 December 2024. Decree No. 147/2024/ND-CP, promulgated on 9 November 2024, supersedes the previous Decree No. 72/2013/ND-CP and its amendments.

    This comprehensive legislation, comprising over 200 pages and 62 appended forms, addresses a wide array of internet and online topics. These include inter alia, internet services, domain names, cross-border information provision, social network services, aggregated information websites, online game services, and app store services.

    Key Provisions

    Cross-Border Information Provision

    Offshore service providers, including those offering social network and app store services on a cross-border basis, are subject to stricter requirements if they either lease data storage in Vietnam or meet a threshold of 100,000 or more total visits per month from Vietnam for six consecutive months. These providers must:

    1. Notify the Authority of Broadcasting and Electronic Information (ABEI) of their contact information
    2. Monitor and remove illegal content
    3. Store and manage user data as required
    4. Authenticate social network user accounts using Vietnamese mobile numbers or identification numbers
    5. Submit annual and ad hoc reports to the ABEI
    6. Handle user complaints

    Only cross-border providers who have notified the ABEI of their contact details may offer live stream and revenue-generating services. Non-compliance may result in blocks and penalties.

    Social Networks

    Decree 147 establishes distinct regimes for offshore and onshore social network services:

    1. Offshore providers meeting the aforementioned threshold must notify the ABEI of their contact information.
    2. Onshore providers reaching 10,000 total visits per month for six consecutive months or 1,000 regular users per month must obtain a Social Network Licence.
    3. Other onshore providers with low traffic must obtain a Notification Certificate from the ABEI.

    The decree also regulates livestream activities by stipulating conditions for social network service providers to offer livestream functions and for social network accounts to conduct livestream activities.

    Online Games

    Foreign organisations and individuals are prohibited from providing online games to service users in Vietnam on a cross-border basis. To offer such services, they must establish a local enterprise in Vietnam.

    This new decree is expected to have a significant impact on both onshore and offshore service providers in the respective fields and may tighten the regulatory landscape for internet services and online information provision in Vietnam.

    “This agreement is not just an economic opportunity. It is a political necessity.” In the current geopolitical context of growing protectionism and significant regional conflicts, Ursula von der Leyen’s statement says a lot.

    Even though there is still a long way to go before the agreement is approved internally in each bloc and comes into force, the milestone is highly significant. It took 25 years from the start of negotiations between Mercosur and the European Union to reach a consensus text. The impacts will be considerable. Together, the blocs represent a GDP of over 22 trillion dollars, and are home to over 700 million people.

    Our aim here is to highlight, in a simplified manner, the most important information about the agreement’s content and its progress, which we will update here at each stage.

    What is it?

    The agreement was signed as a trade treaty, with the main goal of reducing import and export tariffs, eliminating bureaucratic barriers, and facilitating trade between Mercosur countries and European Union members. Additionally, the pact includes commitments in areas such as sustainability, labor rights, technological cooperation, and environmental protection.

    Mercosur (Southern Common Market) is an economic bloc created in 1991 by Brazil, Argentina, Paraguay, and Uruguay. Now, Bolivia and Chile participate as associated members, accessing some trade agreements, but not fully integrated into the common market. On the other hand, the European Union, with its 27 members (20 of which have adopted the common currency), is a broader union with greater economic and social integration compared to Mercosur.

    What does the EU Mercosur agreement include?

    Trade in goods:

    • Reduction or elimination of tariffs on products traded between the blocs, such as meat, grains, fruits, automobiles, wines, and dairy products (the expected reduction will affect over 90% of the traded goods between the blocks).
    • Easier access to European high-tech and industrialized products.

    Trade in services:

    • Expands access to financial services, telecommunications, transportation, and consulting for businesses in both blocs.

    Movement of people:

    • Provides facilities for temporary visas for qualified workers, such as technology professionals and engineers, promoting talent exchange.
    • Encourages educational and cultural cooperation programs.

    Sustainability and environment:

    • Includes commitments to combat deforestation and meet the goals of the Paris Agreement on climate change.
    • Provides penalties for violations of environmental standards.

    Intellectual property and regulations:

    • Protects geographical indications for European cheese, wines, and South American coffee and cachaça.
    • Harmonizes regulatory standards to reduce bureaucracy and avoid technical barriers.

    Labor rights:

    • Commitment to decent working conditions and compliance with International Labor Organization (ILO) standards.

    Which benefits to expect?

    • Access to new markets: Mercosur companies will have easier access to the European market, which has more than 450 million consumers, while European products will become more competitive in South America.
    • Costs reduction: The elimination or reduction of tariffs could lower the prices of products such as wines, cheese, and automobiles and boost South American exports of meat, grains, and fruits.
    • Strengthened diplomatic relations: The agreement symbolizes a bridge of cooperation between two regions historically connected by cultural and economic ties.

    What’s next?

    The signing is only the first step. For the agreement to come into force, it must be ratified by both blocs, and the approval process is quite distinct between them, since Mercosur does not have a common Council or Parliament.

    In the European Union, the ratification process involves multiple institutional steps:

    • Council of the European Union: Ministers from the member states will discuss and approve the text of the agreement. This step is crucial, as each country has representation and may raise specific national concerns.
    • European Parliament: After approval by the Council, the European Parliament, composed of elected deputies, votes to ratify the agreement. The debate at this stage may include environmental, social, and economic impacts.
    • National Parliaments: In cases where the agreement affects shared competencies between the bloc and member states (such as environmental regulations), it must also be approved by the parliaments of each member country. This can be challenging, given that countries like France and Ireland have already expressed specific concerns about agricultural and environmental issues.

    In Mercosur, the approval depends on each member country:

    • National Congresses: The agreement text is submitted to the parliaments of Brazil, Argentina, Paraguay, and Uruguay. Each congress evaluates independently, and approval depends on the political majority in each country.
    • Political Context: Mercosur countries have diverse political realities. In Brazil, for example, environmental issues can spark heated debates, while in Argentina, the impact on agricultural competitiveness may be the focus of discussion.
    • Regional Coordination: Even after national approval, it is necessary to ensure that all Mercosur members ratify the agreement, as the bloc acts as a single negotiating entity.

    Stay tuned: you will find the update here as the processes advance.

    Vietnam has embraced the global minimum tax (GMT) to harmonize its tax policies with global standards. While this new tax regime is anticipated to have certain adverse effects on foreign direct investment (FDI), the Vietnamese government is devising proactive measures to mitigate these repercussions and maintain the country’s appeal as an investment haven.

    Key Ramifications of the GMT for Vietnam

    The GMT mandates multinational corporations (MNCs) with consolidated revenue surpassing €750 million to pay a minimum tax rate of 15%, irrespective of the tax rate in the country where they operate. In Vietnam, this translates to the concept of a qualified domestic minimum top-up tax (QDMTT).

    The QDMTT places an extra tax burden on foreign-invested enterprises (FIEs) that are part of an MNC, potentially deterring them from investing or expanding in Vietnam. This is particularly concerning for industries that heavily rely on tax incentives to attract FDI.

    Vietnam’s Response: Investment Support Fund and Proactive Measures

    In response to the anticipated negative impacts of the GMT, the Vietnamese government has established an investment support fund (Fund) to incentivize investments in targeted sectors. The Fund is primarily funded by proceeds from the State Budget generated by the GMT.

    Eligible enterprises for the Fund are those engaged in high-tech product manufacturing, high-tech enterprises, high-tech application projects, and enterprises with investment projects in research and development centers. Eligibility is based on capital size, annual revenue, industry, or technology utilized.

    Eligible taxpayers can receive cash subsidies for five specific expense categories:

    1. Human resource training and development
    2. Research and development expenses
    3. Fixed asset investments
    4. High-tech manufacturing expenses
    5. Social infrastructure systems

    To qualify for Fund benefits, eligible taxpayers must submit an application dossier to the Fund Office in Hanoi between August 15th and 30th of the year following the incurred Supported Expenses. Each Supported Expense category will have a distinct reimbursement ratio, and support payments will be contingent on the actual expenses incurred by eligible taxpayers.

    In addition to the Fund, the Vietnamese government is also implementing proactive measures to address the concerns of foreign investors. These measures include:

    1. Focusing on targeted industries with high growth potential that align with Vietnam’s strategic development goals
    2. Utilizing the additional revenue collected from top-up tax to enhance infrastructure and labor quality
    3. Considering cash grants for long-term qualified investments in high-tech industries

    Conclusion

    The introduction of the GMT poses challenges for Vietnam in attracting FDI. However, the government’s establishment of the investment support fund and proactive measures demonstrates its commitment to safeguarding the country’s competitiveness as an investment destination. By combining targeted support with infrastructure improvements and incentives for specific industries, Vietnam can mitigate the negative impacts of the GMT and continue to attract foreign investors.

    Summary

    Egypt aims to be Africa’s first green hydrogen producer by incentivizing companies to invest in the sector. Collaborative efforts with Germany and European companies are underway to enhance hydrogen projects and transport. Incentives include financial subsidies, tax exemptions, and administrative advantages, contingent on project conditions like commissioning, foreign funding, local materials use, and community development.

    What is the status of green energy in Egypt and what role does green hydrogen play in this?

    It is currently estimated that Egypt has the potential to generate 350 GW of wind energy and about 650 GW of solar energy per year, as per the Minister of Electricity and Renewable Energy’s (Mohamed Shaker El-Marqabi) declaration. As part of its National Climate Strategy 2050, Egypt has set itself the goal of reducing its carbon emissions, promoting the use of renewable energy sources and using alternative forms of energy, including green hydrogen. The importance the Egyptian government attaches to green hydrogen is evident, not least with the recent cabinet meeting on 17th of May 2023.

    With a view to becoming the first African country to produce green hydrogen, new incentives for green hydrogen and derivatives projects were presented at the cabinet meeting. Based on an investment of 13 billion USD, the legal and financial benefits (new incentive package) that companies in this field can benefit from in the future were presented.

    What agreements exist between Egypt and third countries to promote green hydrogen?

    Agreement between Egypt and Germany on green hydrogen

    The new incentive package was preceded by a meeting between the German-Egyptian Partnership for Green Hydrogen Projects committee and Egyptian officials on the 14th of March 2023. This resulted in a joint roadmap for supporting hydrogen production companies and promoting hydrogen transport and marketing. At this meeting, it was decided that the parties, the Egyptian Minister of International Cooperation (Rania Al-Mashat) and the Egyptian Minister of Public Enterprises (Mahmoud Esmat), will establish a platform to promote the use of green hydrogen.

    At the above-mentioned meeting, Egypt and Germany signed two Memoranda of Understanding (MoU) to enhance cooperation in the field of green hydrogen.

    The Egyptian Government also recently signed other MoUs with seven European leading companies and global alliances to produce new and renewable energy, to establish green hydrogen production complexes in Ain Al-Sokhna and the Red Sea Governorate.

    The German-Egyptian cooperation in the field of green hydrogen follows Egypt’s goal to establish itself as a hub for producing green hydrogen.

    Agreement between Egypt and third countries on green hydrogen

    Egypt has also partnered with the European Union to advance green hydrogen production. Furthermore, in 2022, on the occasion of COP27, Egypt signed a series of MoUs with several international organisations to engage foreign investment in green hydrogen production and make Egypt a transit route for clean energy to Europe.

    MoUs with global companies and alliances have defined the Red Sea Governorate as the location where green hydrogen projects will be carried out in the future.

    Are there investment incentives for the production of green hydrogen in Egypt?

    In the cabinet meeting of 17th of May 2023, the Egyptian Prime Minister Mustafa Madbuli stated that Egypt was offering the “largest” package of investment incentives and facilitations to companies wishing to invest in green hydrogen production projects in Egypt. He further announced the formation of a working group composed of representatives of the authorities involved to elaborate these investment incentives.

    The statement indicated that companies involved in green energy projects in Egypt will benefit from incentives set out in the Law drafted in the cabinet meeting of 17th of May 2023 and Investment Law No. 72 of 2017. This targets companies involved in the “production, storage and export of green hydrogen”.

    What investment incentives for the production of green hydrogen in Egypt are provided for in the draft Law of 17th of May 2023?

    Financial incentives

    Investments in the green hydrogen sector are subsidised in the amount of 33 % to 55 % of the income tax payable. The Ministry of Finance pays the subsidy within 45 days after the deadline for filing the tax return. The subsidy itself is not taxable. The exact conditions for the payment of the subsidy are still to be determined by the Cabinet.

    All machinery, equipment, materials, consumables and vehicles (except private vehicles) used in green hydrogen and derivative projects are exempt from VAT.

    No VAT is levied on exports of green hydrogen and its derivatives.

    The Ministry of Finance pays most of the duties and certification costs associated with setting up the business and all import duties on imported goods used by the establishment. Further, it pays the taxes that would have been levied on the real estate used for the activity, if any.

    Administrative incentives

    Projects in the field of green hydrogen or its derivatives benefit from the so-called golden licence, as it is called in the Investment Law No. 72 of 2017.

    All raw materials, spare parts and vehicles required for operations can be freely imported or exported directly or through distributors without the need for registration in the Importers’ Register.

    The incentives apply to projects and their extensions throughout the contract period if the project agreements are concluded within a maximum of 7 years from the date of commercial commissioning.

    Requirements

    The investment incentives apply when:

    • the project is commissioned within 5 years of the signing of the project agreement
    • at least 70 % of the investment costs come from foreign funds
    • at least 20 % of the locally used materials originate from Egypt
    • training programmes are set up for local workers and know-how is shared
    • the project company draws up a development plan for the communities in which it will operate

    What investment incentives for the production of green hydrogen in Egypt are provided for in the Investment Law No. 72 of 2017?

    The tax incentives granted under the Investment Law No. 72 of 2017 provide for special, general and additional incentives.

    Special incentives

    These are tax reductions limited to 7 years for projects that are started within 3 years (extendable to 6 years) after the provisions of the Law No. 72 of 2017 came into force (i.e. by October 2023). The investment costs consist of equity capital, long-term loans to finance the construction of the project’s movable and immovable assets, and working capital. The tax base is the taxable net profit, which is taxed at the following rates:

    1) Tax exemption on 50 % of the investment costs for the implementation of a project in geographical locations with the greatest development needs (underdeveloped locations) designated by the Central Agency for Public Mobilization and Statistics (CAPMS)

    The law identifies these sites as “Zone A”. According to the implementing regulations, “Zone A” includes:

    • the Suez Canal Economic Zone
    • the Golden Triangle Special Economic Zone
    • the New Administrative Capital Zone
    • the south of Giza province
    • the provinces of Port Said, Ismailia and Suez (east of the canal) connected to the Suez Canal.
    • border provinces, including Red Sea province south of Safaga
    • the provinces in upper Egypt
    • other areas in greatest need of development (to be determined by the Prime Minister)

    2) Tax exemption on 30 % of the investment costs of a project located in the remaining geographical areas outside “Zone A”, referred to as “Zone B”, and operating in certain sectors.

    This includes projects that:

    • are active in the field of renewable energies
    • export their products outside Egypt
    • be carried out by a small or medium-sized (SME)

    General incentives

    Parallel to the special investment incentives, general investment incentives also apply. For example, projects are exempt from certain administrative requirements and fees for a period of 5 years from the date of their registration in the commercial register. Furthermore, temporary duty-free imports and exports are possible.

    Additional incentives

    Additional investment incentives may also be granted by decision of the Council of Ministers:

    • special customs offices for the export or import of the investment project
    • bearing of the value of the utility supply (such as electricity and water supply) of the property intended for the investment project or part thereof by the State
    • partial bearing of the costs of a technical training programme for employees by the State
    • reimbursement of half of the value of the land allocated for industrial projects, provided that the activity was started within two years of the transfer of the land
    • free allocation of land for certain strategic activities
    • under certain conditions, granting of a general permit for the construction, operation and management of the project as well as for the provision of the land required for this purpose. This permit shall also be deemed to be a building permit and shall be effective in its own right without any further action being required. In December 2022, the Egyptian Cabinet granted general approval for several projects.
    • incorporation shares of capital companies subject to the Investment Law No. 72 of 2017 may be traded during the first two fiscal years of the company, subject to the approval of the competent Minister
    • simplified acquisition of real estate, provided it is used for the project

    Takeaways

    • Egypt’s Green Hydrogen Drive: Egypt is strategically embracing green hydrogen production as a pivotal element of its renewable energy vision. The country’s ambitious goals and extensive incentives underscore its commitment to becoming a leading player in the global green energy landscape.
    • International Collaborations: Collaborations with Germany and European partners highlight Egypt’s proactive approach to international cooperation in advancing green hydrogen technologies. Memoranda of Understanding and joint roadmaps are facilitating knowledge exchange and investments for robust hydrogen projects.
    • Comprehensive Incentive Framework: Egypt’s multifaceted incentive framework, including financial subsidies, tax exemptions, and administrative benefits, showcases the government’s determination to attract investments in green hydrogen production. Stringent conditions for benefiting from these incentives emphasize the nation’s dedication to sustainable practices and local community development.

    Paula Gaspar Álvarez Novoa

    Practice areas

    • Arbitration
    • Family
    • Franchising
    • Litigation
    • Real estate
    Contact Paula

    Contact Paula





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      Saudi Arabia – Draft Rules on Regional Headquarters (RHQ): A Call to Multinational Enterprises

      26 September 2025

      • Saudi Arabia
      • Corporate
      • Foreign investments
      • Tax

      Executive Summary

      The African Continental Free Trade Area (AfCFTA) remains one of the most ambitious integration projects in the world. Yet, several years into its operational phase, it has not (yet) delivered the structural shift many expected. A recent analysis underscores the gap between political momentum and economic reality: implementation remains uneven, the agreement is still used by only a portion of participating states, and non-tariff barriers and infrastructure deficits continue to dominate the cost of doing business across borders.  For Egypt, the opportunity is still real — but it depends less on treaty headlines and more on enabling conditions: trade logistics, customs efficiency, regulatory convergence, and competitive industrial capacity. 

      Looking Back: The Promise of a Single African Market

      When the AfCFTA was launched, expectations were understandably high. A continent-wide trade framework was supposed to reduce tariffs, facilitate trade in goods and services, and strengthen regional value chains — with the broader goal of moving African economies up the value ladder.

      In my 2022 article, I asked whether AfCFTA could become a game changer for Egypt, given Egypt’s industrial base, strategic geography, and the potential to diversify export markets beyond traditional partners. (For background, see the earlier article here”).

      The Reality Check: Intra-African Trade Remains Structurally Weak

      Several years later, the interim assessment is sobering. As the Frankfurter Allgemeine Zeitung (FAZ) recently put it, AfCFTA is not a “game changer” yet, and only about half of member states currently meet the practical prerequisites to trade under the agreement.

      A deeper reason is structural: no other world region trades so little with itself, and while statistics may undercount informal cross-border flows (especially in food), the overall picture remains unchanged.

      Trade integration cannot deliver transformative outcomes if production, logistics, and institutions do not support scale.

      Implementation Has Been Slow — and Often Symbolic

      Operationalisation did not start with full-scale liberalisation. Instead, the AfCFTA began with a pilot approach: the Guided Trade Initiative (GTI) launched in October 2022, initially with eight states, later joined by additional countries, including Nigeria and South Africa by spring 2025.

      The GTI created valuable learning effects, but it also underlined a key point: early progress was often presented through symbolic deals, while product coverage and volumes remained limited. FAZ highlights that only selected goods could be traded duty-free and that key sectors remained constrained for a long time due to missing or unresolved technical rules.

      A pilot, however, cannot substitute for full operational certainty — the kind businesses need to restructure supply chains and invest.

      Tariffs Are Not the Main Barrier — Trade Costs Are

      AfCFTA is frequently discussed in terms of tariff liberalisation. Yet, evidence suggests that the largest gains do not come from tariffs but from reducing non-tariff barriers and improving trade infrastructure.

      FAZ points to a central reality: tariffs tend to add around 20–30% to intra-African trade costs, whereas non-tariff costs can be far higher — driven by bureaucracy, lack of harmonised standards, inefficient border processes, and transport barriers.

      This is the crux: even with reduced tariffs, trade will not expand meaningfully if goods still cannot move cheaply, quickly, and predictably.

      Integration Complexity and Distributional Politics

      Africa’s integration landscape is shaped by multiple overlapping regional economic communities and trade regimes. This creates legal and administrative complexity — often described as an integration “spaghetti bowl.” FAZ notes the challenge of coordination and the continued fragmentation of rules.

      There is also a political economy dimension. Intra-African trade is heavily influenced by a small number of larger economies — and the distribution of benefits matters. FAZ highlights the dominance of major players (notably South Africa) and the concern that tariff liberalisation alone may entrench existing industrial advantages.

      Where governments expect asymmetric outcomes, resistance often takes the form of delay, narrow implementation, or persistent non-tariff barriers.

      What This Means for Egypt: The Opportunity Is Real — But Conditional

      Egypt’s strategic case for AfCFTA participation remains strong: industrial potential, geographic location, and the opportunity to access and shape growing markets. But the experience so far suggests that the treaty text alone does not generate trade flows.

      For Egypt’s private sector, the decisive factors are practical:

      • predictable and efficient customs clearance and border procedures,
      • logistics corridors and port efficiency,
      • regulatory convergence (standards, certification, compliance),
      • stable access to trade finance and payments,
      • competitive energy and production conditions for manufacturing and processing.

      AfCFTA can support these developments — but it cannot replace them.

      The “Game Changer” Pathway: What Must Happen Next

      FAZ concludes that AfCFTA will only become truly impactful if it is paired with the fundamentals: major infrastructure investment, stronger production and processing capacity, and a credible industrial policy.

      At the same time, Africa faces a classic chicken-and-egg problem: without development there is limited investment appeal; without investment there is limited development.

      For Egypt and its partners, a pragmatic strategy would be to:

      1. treat AfCFTA as a platform for real trade-cost reduction, not only tariff debates;
      2. focus on a limited number of scalable corridors and sectors where regional value chains can realistically grow;
      3. strengthen implementation capacity so that preferences become usable for firms — especially SMEs;
      4. enhance legal certainty and dispute resolution reliability for cross-border commerce.

      Conclusion

      AfCFTA remains a landmark achievement in terms of political commitment. But as of today, it has not yet been the “game changer” many hoped for.

      For Egypt, the key question is no longer whether AfCFTA is visionary — it is. The question is whether governments and businesses can translate it into lower real trade costs, higher competitiveness, and bankable cross-border transactions. If those enabling conditions improve, AfCFTA’s promise can still become commercial reality.

      Relocating to Spain for professional reasons is often an exciting step: a new career opportunity, a different lifestyle, and, in many cases, an improved quality of life. However, in practice, the most complex issues rarely arise from employment itself, but from the legal and tax implications surrounding housing.

      Before signing a lease or purchasing a property, it is essential to understand your administrative and tax position in Spain. A proper legal assessment at the outset can prevent costly complications later.

      Immigration Status: The Essential Starting Point

      Not all foreign nationals are in the same legal position.

      Citizens of the European Union may reside and work in Spain, but they must obtain a Foreigner Identification Number (NIE), register with the Central Register of Foreign Nationals, and register their address (empadronamiento) in the municipality where they reside.

      Non-EU nationals, on the other hand, must first secure the appropriate visa or residence and work authorization, and subsequently obtain a Foreigner Identity Card (TIE).

      This is not a mere administrative formality. Without a regularized status, practical issues may arise, including difficulties opening a bank account, setting up utilities, demonstrating financial solvency to landlords, or formalizing deeds before a notary.

      Renting in Spain: What to Review Before Signing

      Residential leases in Spain are governed by the Urban Leases Act (Ley de Arrendamientos Urbanos). Although legal residence is not technically required to sign a lease agreement, landlords often ask for additional guarantees if the tenant has recently arrived in the country.

      It is important to review carefully:

      • The agreed duration of the lease
      • Rent update mechanisms
      • Security deposit and additional guarantees
      • Early termination clauses

      Entering into a lease under time pressure, without fully understanding these terms, can result in financial obligations that may not align with the realities of an international relocation.

      Purchasing Property: Legal Access and Tax Implications

      Foreign nationals may freely acquire real estate in Spain, regardless of residency status. There are no nationality-based restrictions on ownership.

      However, property acquisition has significant tax consequences that should be assessed in advance.

      For resale properties, the Transfer Tax (Impuesto sobre Transmisiones Patrimoniales) applies, with rates varying depending on the Autonomous Community. For newly built properties, VAT (IVA) and Stamp Duty (Actos Jurídicos Documentados) are payable. Notarial and Land Registry fees must also be considered.

      The transaction must be executed through a public deed before a Spanish notary and subsequently registered at the Land Registry to ensure full legal protection against third parties.

      Tax Residency: A Determining Factor

      One of the most critical issues is whether the relocating professional becomes a tax resident in Spain.

      As a general rule, tax residence is acquired by spending more than 183 days in Spain during a calendar year or by having the primary center of economic interests located in Spain. This determination is based on objective criteria and is not dependent solely on municipal registration.

      The distinction is substantial:

      • Spanish tax residents are taxed on their worldwide income.
      • Non-residents are taxed only on income obtained in Spain, under the Non-Resident Income Tax regime.

      Even if a property is not rented, owners may be required to declare imputed income if it does not qualify as their primary residence.

      Coordination with the Country of Origin

      Relocating to Spain does not automatically eliminate tax obligations in the country of origin. Spain has signed numerous double taxation treaties, but their application requires case-by-case analysis.

      Inadequate planning may lead to dual taxation, residency conflicts, or subsequent inquiries from tax authorities in either jurisdiction.

      Plan Before You Commit

      The correct sequence does not begin with signing a lease or reserving a property. It begins with

      • clarifying immigration status
      • defining tax residence, and
      • assessing the legal and financial implications of each decision.

      Housing is not merely a real estate matter. It is a legal and economic commitment with medium- and long-term consequences.

      When a professional move involves crossing borders, careful planning is not optional. It is a fundamental step in protecting both personal stability and the success of the new professional chapter.

      New Regulatory Framework for RHQs: Tax Relief, Substantive Presence, and Streamlined Licensing

      Saudi Arabia has released the long-awaited draft of the “Rules Regulating the Licensing and Supervision of Regional Headquarters of Multinational Companies,” issued pursuant to Cabinet Resolution No. (338) dated 23/4/1445H. This regulatory framework, currently open for public consultation, forms part of the Kingdom’s ambitious Vision 2030 strategy to establish Saudi Arabia as the prime regional base for multinational enterprises (MNEs) operating in the Middle East and North Africa (MENA) region.

      Far beyond mere tax incentives, the draft Rules introduce a binding, structured regime that combines regulatory clarity with strict compliance obligations and long-term benefits. The most salient features include the following.

      30-Year Tax Holiday

      Entities licensed as RHQs will enjoy a 0% income tax rate and a 0% withholding tax rate on dividends, related-party payments, and payments for services essential to RHQ activity. These tax incentives are granted for a period of 30 years, renewable under conditions set by the Ministry of Investment.

      Operational Substance Requirements: RHQ Functions and Compliance

      At the core of the RHQ regime lies the requirement for substantial and sustained business presence in the Kingdom. Licensed RHQs must activate both mandatory and optional activities as defined in Article 7 of the Rules:

      Mandatory Activities (to be activated within the first year):

      • Preparation and implementation of the regional strategy;
      • Strategic coordination of the MNE’s operations in the region;
      • Selection of products and services offered in the region;
      • M&A support;
      • Financial performance review;
      • Budget planning for regional operations;
      • Coordination of business units across MENA;
      • Market research and competitor analysis;
      • Identification of new market opportunities;
      • Marketing strategy development;
      • Preparation of operational and financial reports.

      Optional Activities (minimum of three to be activated): These include, among others:

      • Research, development and innovation;
      • Sales and marketing;
      • Human resources and training;
      • Financial management, foreign exchange and treasury services;
      • Legal consultancy, compliance, internal audit;
      • Logistics, IP management, production, and technical support.

      The selected optional activities must be aligned with the MNE’s global business strategy and must be regionally anchored.

      Additional Substantive Requirements

      • Minimum of 15 employees in the first year;
      • At least 3 senior executives must be based in the Kingdom and must represent the top decision-making authority for the region;
      • RHQ staff must reside in Saudi Arabia, be dedicated full-time, be licensed locally, and receive remuneration through Saudi bank accounts;
      • RHQ operations must be exclusively performed within the Kingdom.

      Licensing Process and Timing

      The licensing process is clearly defined. Upon submission of the required documentation (commercial records, financials, activity plans), the Ministry of Investment will process the application within 30 working days.

      True Regional Authority and Kingdom-Centric Operations

      Licensed RHQs must hold administrative authority over all regional branches and subsidiaries. The RHQ must operate as the highest strategic, executive, and administrative authority in the MENA region. Furthermore, all RHQ-related activities must be carried out exclusively from within the Kingdom.

      Localization Requirements

      To ensure genuine local presence, the RHQ regime mandates:

      • Saudi residency and work permits for all RHQ personnel;
      • No hybrid or remote models from abroad;
      • Local registration of intellectual property and commercial identifiers;
      • Internal reporting and supervision obligations anchored in Saudi Arabia.

      Is RHQ Establishment Mandatory or Optional?

      While the RHQ license remains optional in principle, it is effectively mandatory for all multinational companies intending to contract with Saudi public sector entities.

      As of 1 January 2024, the Saudi government will only consider public procurement contracts from companies that have an RHQ presence in the Kingdom, unless an express exemption is granted. Companies operating purely in the private sector without government contracts remain unaffected, but will nonetheless benefit from the RHQ regime if they choose to participate.

      This regulatory shift creates a strategic filter: those seeking to participate in Saudi Arabia’s transformation across infrastructure, health, energy, and education must establish a fully embedded regional presence in the Kingdom.

      Conclusion: High-Reward, High-Compliance Environment

      The draft Rules represent a bold step in reshaping the MENA business landscape. Saudi Arabia is setting the bar high: generous tax relief and fast-track licensing are tied to substantive commitments in structure, personnel, and governance. For MNEs willing to assume regional leadership from within Saudi borders, the opportunity is as attractive as it is demanding.

      A dedicated notary account in Brazil is a legal mechanism that brings greater security, transparency, and reliability to financial transactions. Regulated under Law 8.935/1994 and Provision No. 197/2025, this service allows notaries to receive, manage, and release funds only after contractual conditions have been fulfilled. By ensuring segregation of assets, traceability, and impartial oversight, dedicated notary accounts provide an effective escrow-like solution for real estate deals, mergers and acquisitions, import/export operations, high-value asset purchases, and complex commercial contracts. This tool not only reduces legal risks and potential disputes but also strengthens trust between parties by guaranteeing that payments are safeguarded until obligations are met.

      The legal basis can be found in Law 8.935/1994, § 1 of art. 7-A, which allows notaries to receive, deposit, and manage amounts related to legal transactions, with transactions subject to objectively verifiable facts/conditions. Provision No. 197, dated June 13, 2025, regulates, at the national level, the service of notarial accounts linked to Notary Public Offices.

      Practical applications: among others, in the following transactions:

      • Real estate: guarantee that the down payment and settlement amounts will be secured in a specific account. This mitigates the risk of misappropriation of funds and ensures that the money will be released only after all contractual conditions have been met.
      • M&A: the linked notarial account creates a standardized escrow mechanism for the payment of price/holdbacks/earn-outs and conditional obligations.
      • Purchase and Sale of High-Value Movable Property: the linked account can be used to guarantee payment. The buyer deposits the amount and the seller knows that the money is safe, being released only after the transfer of ownership and delivery of the goods.
      • Import and Export: the transaction amount can be deposited with the notary and released to the exporter only after confirmation of delivery of the goods in the destination country, for example.
      • Guarantee of Obligations: In any contract that provides for the payment of a sum of money as a guarantee, the notary account can be used to provide greater security to the parties.
      • Supply, EPC/turnkey, and construction contracts: performance retentions, milestone acceptance (commissioning, as-built, issuance of ART/CREA), and payment against formal acceptance.
      • Contractual joint ventures and commercial partnerships: advances conditional on licenses, authorizations, or competitive approval, where applicable.

      Reduction of Legal Risks: The use of linked accounts reduces the chances of litigation related to lack of clarity about the origin and destination of funds. Companies can clearly demonstrate that payments were made and held by an impartial and secure institution.

      Operational structure: limited to banking entities affiliated with the CNB, which must ensure the segregation of assets, traceability through audit trails, and proof of all transactions. The authorization of the delegate requires prior accreditation and electronic registration of the essential details of the transaction and its conditions in the CNB system, with access restricted to the parties and the notary.

      Specific Purpose: amounts received as payment, guarantee, or advance payment as a result of notarial acts must be deposited in a bank account linked to the specific act and may only be moved for the purpose for which they are intended.

      Transparency and Traceability: With the linked notarial account, it is possible to clearly track the financial flow of each transaction, which increases transparency for all parties and for supervisory bodies.

      Verification of conditions and release. Once the objective conditions have been met, the notary authorizes the transfer to the recipients and files the proof of verification. In the event of a dispute between the parties, the notary suspends any movement, draws up a notarial deed, and advises on a consensual or judicial solution, without deciding on the effectiveness/termination of the transaction; if the transaction is frustrated and no solution is found, the procedure is terminated and the amounts are returned to the depositor, in accordance with the agreed clauses.

      Confidentiality and access. In transactions with a confidentiality clause, the notary public maintains confidentiality and does not issue certificates regarding the content of the transaction; documents are accessible only for correctional purposes or by court order.

      Remuneration and costs. The notary’s remuneration for the notarial account service is paid by the financial institution under the terms of the agreement, and the transfer of additional costs to the user is prohibited, without prejudice to fees for any related notarial acts.

      The Government of Vietnam has issued a new decree governing internet services and online information, which shall come into force on 25 December 2024. Decree No. 147/2024/ND-CP, promulgated on 9 November 2024, supersedes the previous Decree No. 72/2013/ND-CP and its amendments.

      This comprehensive legislation, comprising over 200 pages and 62 appended forms, addresses a wide array of internet and online topics. These include inter alia, internet services, domain names, cross-border information provision, social network services, aggregated information websites, online game services, and app store services.

      Key Provisions

      Cross-Border Information Provision

      Offshore service providers, including those offering social network and app store services on a cross-border basis, are subject to stricter requirements if they either lease data storage in Vietnam or meet a threshold of 100,000 or more total visits per month from Vietnam for six consecutive months. These providers must:

      1. Notify the Authority of Broadcasting and Electronic Information (ABEI) of their contact information
      2. Monitor and remove illegal content
      3. Store and manage user data as required
      4. Authenticate social network user accounts using Vietnamese mobile numbers or identification numbers
      5. Submit annual and ad hoc reports to the ABEI
      6. Handle user complaints

      Only cross-border providers who have notified the ABEI of their contact details may offer live stream and revenue-generating services. Non-compliance may result in blocks and penalties.

      Social Networks

      Decree 147 establishes distinct regimes for offshore and onshore social network services:

      1. Offshore providers meeting the aforementioned threshold must notify the ABEI of their contact information.
      2. Onshore providers reaching 10,000 total visits per month for six consecutive months or 1,000 regular users per month must obtain a Social Network Licence.
      3. Other onshore providers with low traffic must obtain a Notification Certificate from the ABEI.

      The decree also regulates livestream activities by stipulating conditions for social network service providers to offer livestream functions and for social network accounts to conduct livestream activities.

      Online Games

      Foreign organisations and individuals are prohibited from providing online games to service users in Vietnam on a cross-border basis. To offer such services, they must establish a local enterprise in Vietnam.

      This new decree is expected to have a significant impact on both onshore and offshore service providers in the respective fields and may tighten the regulatory landscape for internet services and online information provision in Vietnam.

      “This agreement is not just an economic opportunity. It is a political necessity.” In the current geopolitical context of growing protectionism and significant regional conflicts, Ursula von der Leyen’s statement says a lot.

      Even though there is still a long way to go before the agreement is approved internally in each bloc and comes into force, the milestone is highly significant. It took 25 years from the start of negotiations between Mercosur and the European Union to reach a consensus text. The impacts will be considerable. Together, the blocs represent a GDP of over 22 trillion dollars, and are home to over 700 million people.

      Our aim here is to highlight, in a simplified manner, the most important information about the agreement’s content and its progress, which we will update here at each stage.

      What is it?

      The agreement was signed as a trade treaty, with the main goal of reducing import and export tariffs, eliminating bureaucratic barriers, and facilitating trade between Mercosur countries and European Union members. Additionally, the pact includes commitments in areas such as sustainability, labor rights, technological cooperation, and environmental protection.

      Mercosur (Southern Common Market) is an economic bloc created in 1991 by Brazil, Argentina, Paraguay, and Uruguay. Now, Bolivia and Chile participate as associated members, accessing some trade agreements, but not fully integrated into the common market. On the other hand, the European Union, with its 27 members (20 of which have adopted the common currency), is a broader union with greater economic and social integration compared to Mercosur.

      What does the EU Mercosur agreement include?

      Trade in goods:

      • Reduction or elimination of tariffs on products traded between the blocs, such as meat, grains, fruits, automobiles, wines, and dairy products (the expected reduction will affect over 90% of the traded goods between the blocks).
      • Easier access to European high-tech and industrialized products.

      Trade in services:

      • Expands access to financial services, telecommunications, transportation, and consulting for businesses in both blocs.

      Movement of people:

      • Provides facilities for temporary visas for qualified workers, such as technology professionals and engineers, promoting talent exchange.
      • Encourages educational and cultural cooperation programs.

      Sustainability and environment:

      • Includes commitments to combat deforestation and meet the goals of the Paris Agreement on climate change.
      • Provides penalties for violations of environmental standards.

      Intellectual property and regulations:

      • Protects geographical indications for European cheese, wines, and South American coffee and cachaça.
      • Harmonizes regulatory standards to reduce bureaucracy and avoid technical barriers.

      Labor rights:

      • Commitment to decent working conditions and compliance with International Labor Organization (ILO) standards.

      Which benefits to expect?

      • Access to new markets: Mercosur companies will have easier access to the European market, which has more than 450 million consumers, while European products will become more competitive in South America.
      • Costs reduction: The elimination or reduction of tariffs could lower the prices of products such as wines, cheese, and automobiles and boost South American exports of meat, grains, and fruits.
      • Strengthened diplomatic relations: The agreement symbolizes a bridge of cooperation between two regions historically connected by cultural and economic ties.

      What’s next?

      The signing is only the first step. For the agreement to come into force, it must be ratified by both blocs, and the approval process is quite distinct between them, since Mercosur does not have a common Council or Parliament.

      In the European Union, the ratification process involves multiple institutional steps:

      • Council of the European Union: Ministers from the member states will discuss and approve the text of the agreement. This step is crucial, as each country has representation and may raise specific national concerns.
      • European Parliament: After approval by the Council, the European Parliament, composed of elected deputies, votes to ratify the agreement. The debate at this stage may include environmental, social, and economic impacts.
      • National Parliaments: In cases where the agreement affects shared competencies between the bloc and member states (such as environmental regulations), it must also be approved by the parliaments of each member country. This can be challenging, given that countries like France and Ireland have already expressed specific concerns about agricultural and environmental issues.

      In Mercosur, the approval depends on each member country:

      • National Congresses: The agreement text is submitted to the parliaments of Brazil, Argentina, Paraguay, and Uruguay. Each congress evaluates independently, and approval depends on the political majority in each country.
      • Political Context: Mercosur countries have diverse political realities. In Brazil, for example, environmental issues can spark heated debates, while in Argentina, the impact on agricultural competitiveness may be the focus of discussion.
      • Regional Coordination: Even after national approval, it is necessary to ensure that all Mercosur members ratify the agreement, as the bloc acts as a single negotiating entity.

      Stay tuned: you will find the update here as the processes advance.

      Vietnam has embraced the global minimum tax (GMT) to harmonize its tax policies with global standards. While this new tax regime is anticipated to have certain adverse effects on foreign direct investment (FDI), the Vietnamese government is devising proactive measures to mitigate these repercussions and maintain the country’s appeal as an investment haven.

      Key Ramifications of the GMT for Vietnam

      The GMT mandates multinational corporations (MNCs) with consolidated revenue surpassing €750 million to pay a minimum tax rate of 15%, irrespective of the tax rate in the country where they operate. In Vietnam, this translates to the concept of a qualified domestic minimum top-up tax (QDMTT).

      The QDMTT places an extra tax burden on foreign-invested enterprises (FIEs) that are part of an MNC, potentially deterring them from investing or expanding in Vietnam. This is particularly concerning for industries that heavily rely on tax incentives to attract FDI.

      Vietnam’s Response: Investment Support Fund and Proactive Measures

      In response to the anticipated negative impacts of the GMT, the Vietnamese government has established an investment support fund (Fund) to incentivize investments in targeted sectors. The Fund is primarily funded by proceeds from the State Budget generated by the GMT.

      Eligible enterprises for the Fund are those engaged in high-tech product manufacturing, high-tech enterprises, high-tech application projects, and enterprises with investment projects in research and development centers. Eligibility is based on capital size, annual revenue, industry, or technology utilized.

      Eligible taxpayers can receive cash subsidies for five specific expense categories:

      1. Human resource training and development
      2. Research and development expenses
      3. Fixed asset investments
      4. High-tech manufacturing expenses
      5. Social infrastructure systems

      To qualify for Fund benefits, eligible taxpayers must submit an application dossier to the Fund Office in Hanoi between August 15th and 30th of the year following the incurred Supported Expenses. Each Supported Expense category will have a distinct reimbursement ratio, and support payments will be contingent on the actual expenses incurred by eligible taxpayers.

      In addition to the Fund, the Vietnamese government is also implementing proactive measures to address the concerns of foreign investors. These measures include:

      1. Focusing on targeted industries with high growth potential that align with Vietnam’s strategic development goals
      2. Utilizing the additional revenue collected from top-up tax to enhance infrastructure and labor quality
      3. Considering cash grants for long-term qualified investments in high-tech industries

      Conclusion

      The introduction of the GMT poses challenges for Vietnam in attracting FDI. However, the government’s establishment of the investment support fund and proactive measures demonstrates its commitment to safeguarding the country’s competitiveness as an investment destination. By combining targeted support with infrastructure improvements and incentives for specific industries, Vietnam can mitigate the negative impacts of the GMT and continue to attract foreign investors.

      Summary

      Egypt aims to be Africa’s first green hydrogen producer by incentivizing companies to invest in the sector. Collaborative efforts with Germany and European companies are underway to enhance hydrogen projects and transport. Incentives include financial subsidies, tax exemptions, and administrative advantages, contingent on project conditions like commissioning, foreign funding, local materials use, and community development.

      What is the status of green energy in Egypt and what role does green hydrogen play in this?

      It is currently estimated that Egypt has the potential to generate 350 GW of wind energy and about 650 GW of solar energy per year, as per the Minister of Electricity and Renewable Energy’s (Mohamed Shaker El-Marqabi) declaration. As part of its National Climate Strategy 2050, Egypt has set itself the goal of reducing its carbon emissions, promoting the use of renewable energy sources and using alternative forms of energy, including green hydrogen. The importance the Egyptian government attaches to green hydrogen is evident, not least with the recent cabinet meeting on 17th of May 2023.

      With a view to becoming the first African country to produce green hydrogen, new incentives for green hydrogen and derivatives projects were presented at the cabinet meeting. Based on an investment of 13 billion USD, the legal and financial benefits (new incentive package) that companies in this field can benefit from in the future were presented.

      What agreements exist between Egypt and third countries to promote green hydrogen?

      Agreement between Egypt and Germany on green hydrogen

      The new incentive package was preceded by a meeting between the German-Egyptian Partnership for Green Hydrogen Projects committee and Egyptian officials on the 14th of March 2023. This resulted in a joint roadmap for supporting hydrogen production companies and promoting hydrogen transport and marketing. At this meeting, it was decided that the parties, the Egyptian Minister of International Cooperation (Rania Al-Mashat) and the Egyptian Minister of Public Enterprises (Mahmoud Esmat), will establish a platform to promote the use of green hydrogen.

      At the above-mentioned meeting, Egypt and Germany signed two Memoranda of Understanding (MoU) to enhance cooperation in the field of green hydrogen.

      The Egyptian Government also recently signed other MoUs with seven European leading companies and global alliances to produce new and renewable energy, to establish green hydrogen production complexes in Ain Al-Sokhna and the Red Sea Governorate.

      The German-Egyptian cooperation in the field of green hydrogen follows Egypt’s goal to establish itself as a hub for producing green hydrogen.

      Agreement between Egypt and third countries on green hydrogen

      Egypt has also partnered with the European Union to advance green hydrogen production. Furthermore, in 2022, on the occasion of COP27, Egypt signed a series of MoUs with several international organisations to engage foreign investment in green hydrogen production and make Egypt a transit route for clean energy to Europe.

      MoUs with global companies and alliances have defined the Red Sea Governorate as the location where green hydrogen projects will be carried out in the future.

      Are there investment incentives for the production of green hydrogen in Egypt?

      In the cabinet meeting of 17th of May 2023, the Egyptian Prime Minister Mustafa Madbuli stated that Egypt was offering the “largest” package of investment incentives and facilitations to companies wishing to invest in green hydrogen production projects in Egypt. He further announced the formation of a working group composed of representatives of the authorities involved to elaborate these investment incentives.

      The statement indicated that companies involved in green energy projects in Egypt will benefit from incentives set out in the Law drafted in the cabinet meeting of 17th of May 2023 and Investment Law No. 72 of 2017. This targets companies involved in the “production, storage and export of green hydrogen”.

      What investment incentives for the production of green hydrogen in Egypt are provided for in the draft Law of 17th of May 2023?

      Financial incentives

      Investments in the green hydrogen sector are subsidised in the amount of 33 % to 55 % of the income tax payable. The Ministry of Finance pays the subsidy within 45 days after the deadline for filing the tax return. The subsidy itself is not taxable. The exact conditions for the payment of the subsidy are still to be determined by the Cabinet.

      All machinery, equipment, materials, consumables and vehicles (except private vehicles) used in green hydrogen and derivative projects are exempt from VAT.

      No VAT is levied on exports of green hydrogen and its derivatives.

      The Ministry of Finance pays most of the duties and certification costs associated with setting up the business and all import duties on imported goods used by the establishment. Further, it pays the taxes that would have been levied on the real estate used for the activity, if any.

      Administrative incentives

      Projects in the field of green hydrogen or its derivatives benefit from the so-called golden licence, as it is called in the Investment Law No. 72 of 2017.

      All raw materials, spare parts and vehicles required for operations can be freely imported or exported directly or through distributors without the need for registration in the Importers’ Register.

      The incentives apply to projects and their extensions throughout the contract period if the project agreements are concluded within a maximum of 7 years from the date of commercial commissioning.

      Requirements

      The investment incentives apply when:

      • the project is commissioned within 5 years of the signing of the project agreement
      • at least 70 % of the investment costs come from foreign funds
      • at least 20 % of the locally used materials originate from Egypt
      • training programmes are set up for local workers and know-how is shared
      • the project company draws up a development plan for the communities in which it will operate

      What investment incentives for the production of green hydrogen in Egypt are provided for in the Investment Law No. 72 of 2017?

      The tax incentives granted under the Investment Law No. 72 of 2017 provide for special, general and additional incentives.

      Special incentives

      These are tax reductions limited to 7 years for projects that are started within 3 years (extendable to 6 years) after the provisions of the Law No. 72 of 2017 came into force (i.e. by October 2023). The investment costs consist of equity capital, long-term loans to finance the construction of the project’s movable and immovable assets, and working capital. The tax base is the taxable net profit, which is taxed at the following rates:

      1) Tax exemption on 50 % of the investment costs for the implementation of a project in geographical locations with the greatest development needs (underdeveloped locations) designated by the Central Agency for Public Mobilization and Statistics (CAPMS)

      The law identifies these sites as “Zone A”. According to the implementing regulations, “Zone A” includes:

      • the Suez Canal Economic Zone
      • the Golden Triangle Special Economic Zone
      • the New Administrative Capital Zone
      • the south of Giza province
      • the provinces of Port Said, Ismailia and Suez (east of the canal) connected to the Suez Canal.
      • border provinces, including Red Sea province south of Safaga
      • the provinces in upper Egypt
      • other areas in greatest need of development (to be determined by the Prime Minister)

      2) Tax exemption on 30 % of the investment costs of a project located in the remaining geographical areas outside “Zone A”, referred to as “Zone B”, and operating in certain sectors.

      This includes projects that:

      • are active in the field of renewable energies
      • export their products outside Egypt
      • be carried out by a small or medium-sized (SME)

      General incentives

      Parallel to the special investment incentives, general investment incentives also apply. For example, projects are exempt from certain administrative requirements and fees for a period of 5 years from the date of their registration in the commercial register. Furthermore, temporary duty-free imports and exports are possible.

      Additional incentives

      Additional investment incentives may also be granted by decision of the Council of Ministers:

      • special customs offices for the export or import of the investment project
      • bearing of the value of the utility supply (such as electricity and water supply) of the property intended for the investment project or part thereof by the State
      • partial bearing of the costs of a technical training programme for employees by the State
      • reimbursement of half of the value of the land allocated for industrial projects, provided that the activity was started within two years of the transfer of the land
      • free allocation of land for certain strategic activities
      • under certain conditions, granting of a general permit for the construction, operation and management of the project as well as for the provision of the land required for this purpose. This permit shall also be deemed to be a building permit and shall be effective in its own right without any further action being required. In December 2022, the Egyptian Cabinet granted general approval for several projects.
      • incorporation shares of capital companies subject to the Investment Law No. 72 of 2017 may be traded during the first two fiscal years of the company, subject to the approval of the competent Minister
      • simplified acquisition of real estate, provided it is used for the project

      Takeaways

      • Egypt’s Green Hydrogen Drive: Egypt is strategically embracing green hydrogen production as a pivotal element of its renewable energy vision. The country’s ambitious goals and extensive incentives underscore its commitment to becoming a leading player in the global green energy landscape.
      • International Collaborations: Collaborations with Germany and European partners highlight Egypt’s proactive approach to international cooperation in advancing green hydrogen technologies. Memoranda of Understanding and joint roadmaps are facilitating knowledge exchange and investments for robust hydrogen projects.
      • Comprehensive Incentive Framework: Egypt’s multifaceted incentive framework, including financial subsidies, tax exemptions, and administrative benefits, showcases the government’s determination to attract investments in green hydrogen production. Stringent conditions for benefiting from these incentives emphasize the nation’s dedication to sustainable practices and local community development.

      Christian Ule

      Practice areas

      • Arbitration
      • Contracts
      • Corporate
      • Distribution
      • International trade
      Contact Christian

      Contact Christian





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        Brazil – Dedicated Notary Account

        28 August 2025

        • Brazil
        • Contracts
        • Foreign investments
        • M&A

        Executive Summary

        The African Continental Free Trade Area (AfCFTA) remains one of the most ambitious integration projects in the world. Yet, several years into its operational phase, it has not (yet) delivered the structural shift many expected. A recent analysis underscores the gap between political momentum and economic reality: implementation remains uneven, the agreement is still used by only a portion of participating states, and non-tariff barriers and infrastructure deficits continue to dominate the cost of doing business across borders.  For Egypt, the opportunity is still real — but it depends less on treaty headlines and more on enabling conditions: trade logistics, customs efficiency, regulatory convergence, and competitive industrial capacity. 

        Looking Back: The Promise of a Single African Market

        When the AfCFTA was launched, expectations were understandably high. A continent-wide trade framework was supposed to reduce tariffs, facilitate trade in goods and services, and strengthen regional value chains — with the broader goal of moving African economies up the value ladder.

        In my 2022 article, I asked whether AfCFTA could become a game changer for Egypt, given Egypt’s industrial base, strategic geography, and the potential to diversify export markets beyond traditional partners. (For background, see the earlier article here”).

        The Reality Check: Intra-African Trade Remains Structurally Weak

        Several years later, the interim assessment is sobering. As the Frankfurter Allgemeine Zeitung (FAZ) recently put it, AfCFTA is not a “game changer” yet, and only about half of member states currently meet the practical prerequisites to trade under the agreement.

        A deeper reason is structural: no other world region trades so little with itself, and while statistics may undercount informal cross-border flows (especially in food), the overall picture remains unchanged.

        Trade integration cannot deliver transformative outcomes if production, logistics, and institutions do not support scale.

        Implementation Has Been Slow — and Often Symbolic

        Operationalisation did not start with full-scale liberalisation. Instead, the AfCFTA began with a pilot approach: the Guided Trade Initiative (GTI) launched in October 2022, initially with eight states, later joined by additional countries, including Nigeria and South Africa by spring 2025.

        The GTI created valuable learning effects, but it also underlined a key point: early progress was often presented through symbolic deals, while product coverage and volumes remained limited. FAZ highlights that only selected goods could be traded duty-free and that key sectors remained constrained for a long time due to missing or unresolved technical rules.

        A pilot, however, cannot substitute for full operational certainty — the kind businesses need to restructure supply chains and invest.

        Tariffs Are Not the Main Barrier — Trade Costs Are

        AfCFTA is frequently discussed in terms of tariff liberalisation. Yet, evidence suggests that the largest gains do not come from tariffs but from reducing non-tariff barriers and improving trade infrastructure.

        FAZ points to a central reality: tariffs tend to add around 20–30% to intra-African trade costs, whereas non-tariff costs can be far higher — driven by bureaucracy, lack of harmonised standards, inefficient border processes, and transport barriers.

        This is the crux: even with reduced tariffs, trade will not expand meaningfully if goods still cannot move cheaply, quickly, and predictably.

        Integration Complexity and Distributional Politics

        Africa’s integration landscape is shaped by multiple overlapping regional economic communities and trade regimes. This creates legal and administrative complexity — often described as an integration “spaghetti bowl.” FAZ notes the challenge of coordination and the continued fragmentation of rules.

        There is also a political economy dimension. Intra-African trade is heavily influenced by a small number of larger economies — and the distribution of benefits matters. FAZ highlights the dominance of major players (notably South Africa) and the concern that tariff liberalisation alone may entrench existing industrial advantages.

        Where governments expect asymmetric outcomes, resistance often takes the form of delay, narrow implementation, or persistent non-tariff barriers.

        What This Means for Egypt: The Opportunity Is Real — But Conditional

        Egypt’s strategic case for AfCFTA participation remains strong: industrial potential, geographic location, and the opportunity to access and shape growing markets. But the experience so far suggests that the treaty text alone does not generate trade flows.

        For Egypt’s private sector, the decisive factors are practical:

        • predictable and efficient customs clearance and border procedures,
        • logistics corridors and port efficiency,
        • regulatory convergence (standards, certification, compliance),
        • stable access to trade finance and payments,
        • competitive energy and production conditions for manufacturing and processing.

        AfCFTA can support these developments — but it cannot replace them.

        The “Game Changer” Pathway: What Must Happen Next

        FAZ concludes that AfCFTA will only become truly impactful if it is paired with the fundamentals: major infrastructure investment, stronger production and processing capacity, and a credible industrial policy.

        At the same time, Africa faces a classic chicken-and-egg problem: without development there is limited investment appeal; without investment there is limited development.

        For Egypt and its partners, a pragmatic strategy would be to:

        1. treat AfCFTA as a platform for real trade-cost reduction, not only tariff debates;
        2. focus on a limited number of scalable corridors and sectors where regional value chains can realistically grow;
        3. strengthen implementation capacity so that preferences become usable for firms — especially SMEs;
        4. enhance legal certainty and dispute resolution reliability for cross-border commerce.

        Conclusion

        AfCFTA remains a landmark achievement in terms of political commitment. But as of today, it has not yet been the “game changer” many hoped for.

        For Egypt, the key question is no longer whether AfCFTA is visionary — it is. The question is whether governments and businesses can translate it into lower real trade costs, higher competitiveness, and bankable cross-border transactions. If those enabling conditions improve, AfCFTA’s promise can still become commercial reality.

        Relocating to Spain for professional reasons is often an exciting step: a new career opportunity, a different lifestyle, and, in many cases, an improved quality of life. However, in practice, the most complex issues rarely arise from employment itself, but from the legal and tax implications surrounding housing.

        Before signing a lease or purchasing a property, it is essential to understand your administrative and tax position in Spain. A proper legal assessment at the outset can prevent costly complications later.

        Immigration Status: The Essential Starting Point

        Not all foreign nationals are in the same legal position.

        Citizens of the European Union may reside and work in Spain, but they must obtain a Foreigner Identification Number (NIE), register with the Central Register of Foreign Nationals, and register their address (empadronamiento) in the municipality where they reside.

        Non-EU nationals, on the other hand, must first secure the appropriate visa or residence and work authorization, and subsequently obtain a Foreigner Identity Card (TIE).

        This is not a mere administrative formality. Without a regularized status, practical issues may arise, including difficulties opening a bank account, setting up utilities, demonstrating financial solvency to landlords, or formalizing deeds before a notary.

        Renting in Spain: What to Review Before Signing

        Residential leases in Spain are governed by the Urban Leases Act (Ley de Arrendamientos Urbanos). Although legal residence is not technically required to sign a lease agreement, landlords often ask for additional guarantees if the tenant has recently arrived in the country.

        It is important to review carefully:

        • The agreed duration of the lease
        • Rent update mechanisms
        • Security deposit and additional guarantees
        • Early termination clauses

        Entering into a lease under time pressure, without fully understanding these terms, can result in financial obligations that may not align with the realities of an international relocation.

        Purchasing Property: Legal Access and Tax Implications

        Foreign nationals may freely acquire real estate in Spain, regardless of residency status. There are no nationality-based restrictions on ownership.

        However, property acquisition has significant tax consequences that should be assessed in advance.

        For resale properties, the Transfer Tax (Impuesto sobre Transmisiones Patrimoniales) applies, with rates varying depending on the Autonomous Community. For newly built properties, VAT (IVA) and Stamp Duty (Actos Jurídicos Documentados) are payable. Notarial and Land Registry fees must also be considered.

        The transaction must be executed through a public deed before a Spanish notary and subsequently registered at the Land Registry to ensure full legal protection against third parties.

        Tax Residency: A Determining Factor

        One of the most critical issues is whether the relocating professional becomes a tax resident in Spain.

        As a general rule, tax residence is acquired by spending more than 183 days in Spain during a calendar year or by having the primary center of economic interests located in Spain. This determination is based on objective criteria and is not dependent solely on municipal registration.

        The distinction is substantial:

        • Spanish tax residents are taxed on their worldwide income.
        • Non-residents are taxed only on income obtained in Spain, under the Non-Resident Income Tax regime.

        Even if a property is not rented, owners may be required to declare imputed income if it does not qualify as their primary residence.

        Coordination with the Country of Origin

        Relocating to Spain does not automatically eliminate tax obligations in the country of origin. Spain has signed numerous double taxation treaties, but their application requires case-by-case analysis.

        Inadequate planning may lead to dual taxation, residency conflicts, or subsequent inquiries from tax authorities in either jurisdiction.

        Plan Before You Commit

        The correct sequence does not begin with signing a lease or reserving a property. It begins with

        • clarifying immigration status
        • defining tax residence, and
        • assessing the legal and financial implications of each decision.

        Housing is not merely a real estate matter. It is a legal and economic commitment with medium- and long-term consequences.

        When a professional move involves crossing borders, careful planning is not optional. It is a fundamental step in protecting both personal stability and the success of the new professional chapter.

        New Regulatory Framework for RHQs: Tax Relief, Substantive Presence, and Streamlined Licensing

        Saudi Arabia has released the long-awaited draft of the “Rules Regulating the Licensing and Supervision of Regional Headquarters of Multinational Companies,” issued pursuant to Cabinet Resolution No. (338) dated 23/4/1445H. This regulatory framework, currently open for public consultation, forms part of the Kingdom’s ambitious Vision 2030 strategy to establish Saudi Arabia as the prime regional base for multinational enterprises (MNEs) operating in the Middle East and North Africa (MENA) region.

        Far beyond mere tax incentives, the draft Rules introduce a binding, structured regime that combines regulatory clarity with strict compliance obligations and long-term benefits. The most salient features include the following.

        30-Year Tax Holiday

        Entities licensed as RHQs will enjoy a 0% income tax rate and a 0% withholding tax rate on dividends, related-party payments, and payments for services essential to RHQ activity. These tax incentives are granted for a period of 30 years, renewable under conditions set by the Ministry of Investment.

        Operational Substance Requirements: RHQ Functions and Compliance

        At the core of the RHQ regime lies the requirement for substantial and sustained business presence in the Kingdom. Licensed RHQs must activate both mandatory and optional activities as defined in Article 7 of the Rules:

        Mandatory Activities (to be activated within the first year):

        • Preparation and implementation of the regional strategy;
        • Strategic coordination of the MNE’s operations in the region;
        • Selection of products and services offered in the region;
        • M&A support;
        • Financial performance review;
        • Budget planning for regional operations;
        • Coordination of business units across MENA;
        • Market research and competitor analysis;
        • Identification of new market opportunities;
        • Marketing strategy development;
        • Preparation of operational and financial reports.

        Optional Activities (minimum of three to be activated): These include, among others:

        • Research, development and innovation;
        • Sales and marketing;
        • Human resources and training;
        • Financial management, foreign exchange and treasury services;
        • Legal consultancy, compliance, internal audit;
        • Logistics, IP management, production, and technical support.

        The selected optional activities must be aligned with the MNE’s global business strategy and must be regionally anchored.

        Additional Substantive Requirements

        • Minimum of 15 employees in the first year;
        • At least 3 senior executives must be based in the Kingdom and must represent the top decision-making authority for the region;
        • RHQ staff must reside in Saudi Arabia, be dedicated full-time, be licensed locally, and receive remuneration through Saudi bank accounts;
        • RHQ operations must be exclusively performed within the Kingdom.

        Licensing Process and Timing

        The licensing process is clearly defined. Upon submission of the required documentation (commercial records, financials, activity plans), the Ministry of Investment will process the application within 30 working days.

        True Regional Authority and Kingdom-Centric Operations

        Licensed RHQs must hold administrative authority over all regional branches and subsidiaries. The RHQ must operate as the highest strategic, executive, and administrative authority in the MENA region. Furthermore, all RHQ-related activities must be carried out exclusively from within the Kingdom.

        Localization Requirements

        To ensure genuine local presence, the RHQ regime mandates:

        • Saudi residency and work permits for all RHQ personnel;
        • No hybrid or remote models from abroad;
        • Local registration of intellectual property and commercial identifiers;
        • Internal reporting and supervision obligations anchored in Saudi Arabia.

        Is RHQ Establishment Mandatory or Optional?

        While the RHQ license remains optional in principle, it is effectively mandatory for all multinational companies intending to contract with Saudi public sector entities.

        As of 1 January 2024, the Saudi government will only consider public procurement contracts from companies that have an RHQ presence in the Kingdom, unless an express exemption is granted. Companies operating purely in the private sector without government contracts remain unaffected, but will nonetheless benefit from the RHQ regime if they choose to participate.

        This regulatory shift creates a strategic filter: those seeking to participate in Saudi Arabia’s transformation across infrastructure, health, energy, and education must establish a fully embedded regional presence in the Kingdom.

        Conclusion: High-Reward, High-Compliance Environment

        The draft Rules represent a bold step in reshaping the MENA business landscape. Saudi Arabia is setting the bar high: generous tax relief and fast-track licensing are tied to substantive commitments in structure, personnel, and governance. For MNEs willing to assume regional leadership from within Saudi borders, the opportunity is as attractive as it is demanding.

        A dedicated notary account in Brazil is a legal mechanism that brings greater security, transparency, and reliability to financial transactions. Regulated under Law 8.935/1994 and Provision No. 197/2025, this service allows notaries to receive, manage, and release funds only after contractual conditions have been fulfilled. By ensuring segregation of assets, traceability, and impartial oversight, dedicated notary accounts provide an effective escrow-like solution for real estate deals, mergers and acquisitions, import/export operations, high-value asset purchases, and complex commercial contracts. This tool not only reduces legal risks and potential disputes but also strengthens trust between parties by guaranteeing that payments are safeguarded until obligations are met.

        The legal basis can be found in Law 8.935/1994, § 1 of art. 7-A, which allows notaries to receive, deposit, and manage amounts related to legal transactions, with transactions subject to objectively verifiable facts/conditions. Provision No. 197, dated June 13, 2025, regulates, at the national level, the service of notarial accounts linked to Notary Public Offices.

        Practical applications: among others, in the following transactions:

        • Real estate: guarantee that the down payment and settlement amounts will be secured in a specific account. This mitigates the risk of misappropriation of funds and ensures that the money will be released only after all contractual conditions have been met.
        • M&A: the linked notarial account creates a standardized escrow mechanism for the payment of price/holdbacks/earn-outs and conditional obligations.
        • Purchase and Sale of High-Value Movable Property: the linked account can be used to guarantee payment. The buyer deposits the amount and the seller knows that the money is safe, being released only after the transfer of ownership and delivery of the goods.
        • Import and Export: the transaction amount can be deposited with the notary and released to the exporter only after confirmation of delivery of the goods in the destination country, for example.
        • Guarantee of Obligations: In any contract that provides for the payment of a sum of money as a guarantee, the notary account can be used to provide greater security to the parties.
        • Supply, EPC/turnkey, and construction contracts: performance retentions, milestone acceptance (commissioning, as-built, issuance of ART/CREA), and payment against formal acceptance.
        • Contractual joint ventures and commercial partnerships: advances conditional on licenses, authorizations, or competitive approval, where applicable.

        Reduction of Legal Risks: The use of linked accounts reduces the chances of litigation related to lack of clarity about the origin and destination of funds. Companies can clearly demonstrate that payments were made and held by an impartial and secure institution.

        Operational structure: limited to banking entities affiliated with the CNB, which must ensure the segregation of assets, traceability through audit trails, and proof of all transactions. The authorization of the delegate requires prior accreditation and electronic registration of the essential details of the transaction and its conditions in the CNB system, with access restricted to the parties and the notary.

        Specific Purpose: amounts received as payment, guarantee, or advance payment as a result of notarial acts must be deposited in a bank account linked to the specific act and may only be moved for the purpose for which they are intended.

        Transparency and Traceability: With the linked notarial account, it is possible to clearly track the financial flow of each transaction, which increases transparency for all parties and for supervisory bodies.

        Verification of conditions and release. Once the objective conditions have been met, the notary authorizes the transfer to the recipients and files the proof of verification. In the event of a dispute between the parties, the notary suspends any movement, draws up a notarial deed, and advises on a consensual or judicial solution, without deciding on the effectiveness/termination of the transaction; if the transaction is frustrated and no solution is found, the procedure is terminated and the amounts are returned to the depositor, in accordance with the agreed clauses.

        Confidentiality and access. In transactions with a confidentiality clause, the notary public maintains confidentiality and does not issue certificates regarding the content of the transaction; documents are accessible only for correctional purposes or by court order.

        Remuneration and costs. The notary’s remuneration for the notarial account service is paid by the financial institution under the terms of the agreement, and the transfer of additional costs to the user is prohibited, without prejudice to fees for any related notarial acts.

        The Government of Vietnam has issued a new decree governing internet services and online information, which shall come into force on 25 December 2024. Decree No. 147/2024/ND-CP, promulgated on 9 November 2024, supersedes the previous Decree No. 72/2013/ND-CP and its amendments.

        This comprehensive legislation, comprising over 200 pages and 62 appended forms, addresses a wide array of internet and online topics. These include inter alia, internet services, domain names, cross-border information provision, social network services, aggregated information websites, online game services, and app store services.

        Key Provisions

        Cross-Border Information Provision

        Offshore service providers, including those offering social network and app store services on a cross-border basis, are subject to stricter requirements if they either lease data storage in Vietnam or meet a threshold of 100,000 or more total visits per month from Vietnam for six consecutive months. These providers must:

        1. Notify the Authority of Broadcasting and Electronic Information (ABEI) of their contact information
        2. Monitor and remove illegal content
        3. Store and manage user data as required
        4. Authenticate social network user accounts using Vietnamese mobile numbers or identification numbers
        5. Submit annual and ad hoc reports to the ABEI
        6. Handle user complaints

        Only cross-border providers who have notified the ABEI of their contact details may offer live stream and revenue-generating services. Non-compliance may result in blocks and penalties.

        Social Networks

        Decree 147 establishes distinct regimes for offshore and onshore social network services:

        1. Offshore providers meeting the aforementioned threshold must notify the ABEI of their contact information.
        2. Onshore providers reaching 10,000 total visits per month for six consecutive months or 1,000 regular users per month must obtain a Social Network Licence.
        3. Other onshore providers with low traffic must obtain a Notification Certificate from the ABEI.

        The decree also regulates livestream activities by stipulating conditions for social network service providers to offer livestream functions and for social network accounts to conduct livestream activities.

        Online Games

        Foreign organisations and individuals are prohibited from providing online games to service users in Vietnam on a cross-border basis. To offer such services, they must establish a local enterprise in Vietnam.

        This new decree is expected to have a significant impact on both onshore and offshore service providers in the respective fields and may tighten the regulatory landscape for internet services and online information provision in Vietnam.

        “This agreement is not just an economic opportunity. It is a political necessity.” In the current geopolitical context of growing protectionism and significant regional conflicts, Ursula von der Leyen’s statement says a lot.

        Even though there is still a long way to go before the agreement is approved internally in each bloc and comes into force, the milestone is highly significant. It took 25 years from the start of negotiations between Mercosur and the European Union to reach a consensus text. The impacts will be considerable. Together, the blocs represent a GDP of over 22 trillion dollars, and are home to over 700 million people.

        Our aim here is to highlight, in a simplified manner, the most important information about the agreement’s content and its progress, which we will update here at each stage.

        What is it?

        The agreement was signed as a trade treaty, with the main goal of reducing import and export tariffs, eliminating bureaucratic barriers, and facilitating trade between Mercosur countries and European Union members. Additionally, the pact includes commitments in areas such as sustainability, labor rights, technological cooperation, and environmental protection.

        Mercosur (Southern Common Market) is an economic bloc created in 1991 by Brazil, Argentina, Paraguay, and Uruguay. Now, Bolivia and Chile participate as associated members, accessing some trade agreements, but not fully integrated into the common market. On the other hand, the European Union, with its 27 members (20 of which have adopted the common currency), is a broader union with greater economic and social integration compared to Mercosur.

        What does the EU Mercosur agreement include?

        Trade in goods:

        • Reduction or elimination of tariffs on products traded between the blocs, such as meat, grains, fruits, automobiles, wines, and dairy products (the expected reduction will affect over 90% of the traded goods between the blocks).
        • Easier access to European high-tech and industrialized products.

        Trade in services:

        • Expands access to financial services, telecommunications, transportation, and consulting for businesses in both blocs.

        Movement of people:

        • Provides facilities for temporary visas for qualified workers, such as technology professionals and engineers, promoting talent exchange.
        • Encourages educational and cultural cooperation programs.

        Sustainability and environment:

        • Includes commitments to combat deforestation and meet the goals of the Paris Agreement on climate change.
        • Provides penalties for violations of environmental standards.

        Intellectual property and regulations:

        • Protects geographical indications for European cheese, wines, and South American coffee and cachaça.
        • Harmonizes regulatory standards to reduce bureaucracy and avoid technical barriers.

        Labor rights:

        • Commitment to decent working conditions and compliance with International Labor Organization (ILO) standards.

        Which benefits to expect?

        • Access to new markets: Mercosur companies will have easier access to the European market, which has more than 450 million consumers, while European products will become more competitive in South America.
        • Costs reduction: The elimination or reduction of tariffs could lower the prices of products such as wines, cheese, and automobiles and boost South American exports of meat, grains, and fruits.
        • Strengthened diplomatic relations: The agreement symbolizes a bridge of cooperation between two regions historically connected by cultural and economic ties.

        What’s next?

        The signing is only the first step. For the agreement to come into force, it must be ratified by both blocs, and the approval process is quite distinct between them, since Mercosur does not have a common Council or Parliament.

        In the European Union, the ratification process involves multiple institutional steps:

        • Council of the European Union: Ministers from the member states will discuss and approve the text of the agreement. This step is crucial, as each country has representation and may raise specific national concerns.
        • European Parliament: After approval by the Council, the European Parliament, composed of elected deputies, votes to ratify the agreement. The debate at this stage may include environmental, social, and economic impacts.
        • National Parliaments: In cases where the agreement affects shared competencies between the bloc and member states (such as environmental regulations), it must also be approved by the parliaments of each member country. This can be challenging, given that countries like France and Ireland have already expressed specific concerns about agricultural and environmental issues.

        In Mercosur, the approval depends on each member country:

        • National Congresses: The agreement text is submitted to the parliaments of Brazil, Argentina, Paraguay, and Uruguay. Each congress evaluates independently, and approval depends on the political majority in each country.
        • Political Context: Mercosur countries have diverse political realities. In Brazil, for example, environmental issues can spark heated debates, while in Argentina, the impact on agricultural competitiveness may be the focus of discussion.
        • Regional Coordination: Even after national approval, it is necessary to ensure that all Mercosur members ratify the agreement, as the bloc acts as a single negotiating entity.

        Stay tuned: you will find the update here as the processes advance.

        Vietnam has embraced the global minimum tax (GMT) to harmonize its tax policies with global standards. While this new tax regime is anticipated to have certain adverse effects on foreign direct investment (FDI), the Vietnamese government is devising proactive measures to mitigate these repercussions and maintain the country’s appeal as an investment haven.

        Key Ramifications of the GMT for Vietnam

        The GMT mandates multinational corporations (MNCs) with consolidated revenue surpassing €750 million to pay a minimum tax rate of 15%, irrespective of the tax rate in the country where they operate. In Vietnam, this translates to the concept of a qualified domestic minimum top-up tax (QDMTT).

        The QDMTT places an extra tax burden on foreign-invested enterprises (FIEs) that are part of an MNC, potentially deterring them from investing or expanding in Vietnam. This is particularly concerning for industries that heavily rely on tax incentives to attract FDI.

        Vietnam’s Response: Investment Support Fund and Proactive Measures

        In response to the anticipated negative impacts of the GMT, the Vietnamese government has established an investment support fund (Fund) to incentivize investments in targeted sectors. The Fund is primarily funded by proceeds from the State Budget generated by the GMT.

        Eligible enterprises for the Fund are those engaged in high-tech product manufacturing, high-tech enterprises, high-tech application projects, and enterprises with investment projects in research and development centers. Eligibility is based on capital size, annual revenue, industry, or technology utilized.

        Eligible taxpayers can receive cash subsidies for five specific expense categories:

        1. Human resource training and development
        2. Research and development expenses
        3. Fixed asset investments
        4. High-tech manufacturing expenses
        5. Social infrastructure systems

        To qualify for Fund benefits, eligible taxpayers must submit an application dossier to the Fund Office in Hanoi between August 15th and 30th of the year following the incurred Supported Expenses. Each Supported Expense category will have a distinct reimbursement ratio, and support payments will be contingent on the actual expenses incurred by eligible taxpayers.

        In addition to the Fund, the Vietnamese government is also implementing proactive measures to address the concerns of foreign investors. These measures include:

        1. Focusing on targeted industries with high growth potential that align with Vietnam’s strategic development goals
        2. Utilizing the additional revenue collected from top-up tax to enhance infrastructure and labor quality
        3. Considering cash grants for long-term qualified investments in high-tech industries

        Conclusion

        The introduction of the GMT poses challenges for Vietnam in attracting FDI. However, the government’s establishment of the investment support fund and proactive measures demonstrates its commitment to safeguarding the country’s competitiveness as an investment destination. By combining targeted support with infrastructure improvements and incentives for specific industries, Vietnam can mitigate the negative impacts of the GMT and continue to attract foreign investors.

        Summary

        Egypt aims to be Africa’s first green hydrogen producer by incentivizing companies to invest in the sector. Collaborative efforts with Germany and European companies are underway to enhance hydrogen projects and transport. Incentives include financial subsidies, tax exemptions, and administrative advantages, contingent on project conditions like commissioning, foreign funding, local materials use, and community development.

        What is the status of green energy in Egypt and what role does green hydrogen play in this?

        It is currently estimated that Egypt has the potential to generate 350 GW of wind energy and about 650 GW of solar energy per year, as per the Minister of Electricity and Renewable Energy’s (Mohamed Shaker El-Marqabi) declaration. As part of its National Climate Strategy 2050, Egypt has set itself the goal of reducing its carbon emissions, promoting the use of renewable energy sources and using alternative forms of energy, including green hydrogen. The importance the Egyptian government attaches to green hydrogen is evident, not least with the recent cabinet meeting on 17th of May 2023.

        With a view to becoming the first African country to produce green hydrogen, new incentives for green hydrogen and derivatives projects were presented at the cabinet meeting. Based on an investment of 13 billion USD, the legal and financial benefits (new incentive package) that companies in this field can benefit from in the future were presented.

        What agreements exist between Egypt and third countries to promote green hydrogen?

        Agreement between Egypt and Germany on green hydrogen

        The new incentive package was preceded by a meeting between the German-Egyptian Partnership for Green Hydrogen Projects committee and Egyptian officials on the 14th of March 2023. This resulted in a joint roadmap for supporting hydrogen production companies and promoting hydrogen transport and marketing. At this meeting, it was decided that the parties, the Egyptian Minister of International Cooperation (Rania Al-Mashat) and the Egyptian Minister of Public Enterprises (Mahmoud Esmat), will establish a platform to promote the use of green hydrogen.

        At the above-mentioned meeting, Egypt and Germany signed two Memoranda of Understanding (MoU) to enhance cooperation in the field of green hydrogen.

        The Egyptian Government also recently signed other MoUs with seven European leading companies and global alliances to produce new and renewable energy, to establish green hydrogen production complexes in Ain Al-Sokhna and the Red Sea Governorate.

        The German-Egyptian cooperation in the field of green hydrogen follows Egypt’s goal to establish itself as a hub for producing green hydrogen.

        Agreement between Egypt and third countries on green hydrogen

        Egypt has also partnered with the European Union to advance green hydrogen production. Furthermore, in 2022, on the occasion of COP27, Egypt signed a series of MoUs with several international organisations to engage foreign investment in green hydrogen production and make Egypt a transit route for clean energy to Europe.

        MoUs with global companies and alliances have defined the Red Sea Governorate as the location where green hydrogen projects will be carried out in the future.

        Are there investment incentives for the production of green hydrogen in Egypt?

        In the cabinet meeting of 17th of May 2023, the Egyptian Prime Minister Mustafa Madbuli stated that Egypt was offering the “largest” package of investment incentives and facilitations to companies wishing to invest in green hydrogen production projects in Egypt. He further announced the formation of a working group composed of representatives of the authorities involved to elaborate these investment incentives.

        The statement indicated that companies involved in green energy projects in Egypt will benefit from incentives set out in the Law drafted in the cabinet meeting of 17th of May 2023 and Investment Law No. 72 of 2017. This targets companies involved in the “production, storage and export of green hydrogen”.

        What investment incentives for the production of green hydrogen in Egypt are provided for in the draft Law of 17th of May 2023?

        Financial incentives

        Investments in the green hydrogen sector are subsidised in the amount of 33 % to 55 % of the income tax payable. The Ministry of Finance pays the subsidy within 45 days after the deadline for filing the tax return. The subsidy itself is not taxable. The exact conditions for the payment of the subsidy are still to be determined by the Cabinet.

        All machinery, equipment, materials, consumables and vehicles (except private vehicles) used in green hydrogen and derivative projects are exempt from VAT.

        No VAT is levied on exports of green hydrogen and its derivatives.

        The Ministry of Finance pays most of the duties and certification costs associated with setting up the business and all import duties on imported goods used by the establishment. Further, it pays the taxes that would have been levied on the real estate used for the activity, if any.

        Administrative incentives

        Projects in the field of green hydrogen or its derivatives benefit from the so-called golden licence, as it is called in the Investment Law No. 72 of 2017.

        All raw materials, spare parts and vehicles required for operations can be freely imported or exported directly or through distributors without the need for registration in the Importers’ Register.

        The incentives apply to projects and their extensions throughout the contract period if the project agreements are concluded within a maximum of 7 years from the date of commercial commissioning.

        Requirements

        The investment incentives apply when:

        • the project is commissioned within 5 years of the signing of the project agreement
        • at least 70 % of the investment costs come from foreign funds
        • at least 20 % of the locally used materials originate from Egypt
        • training programmes are set up for local workers and know-how is shared
        • the project company draws up a development plan for the communities in which it will operate

        What investment incentives for the production of green hydrogen in Egypt are provided for in the Investment Law No. 72 of 2017?

        The tax incentives granted under the Investment Law No. 72 of 2017 provide for special, general and additional incentives.

        Special incentives

        These are tax reductions limited to 7 years for projects that are started within 3 years (extendable to 6 years) after the provisions of the Law No. 72 of 2017 came into force (i.e. by October 2023). The investment costs consist of equity capital, long-term loans to finance the construction of the project’s movable and immovable assets, and working capital. The tax base is the taxable net profit, which is taxed at the following rates:

        1) Tax exemption on 50 % of the investment costs for the implementation of a project in geographical locations with the greatest development needs (underdeveloped locations) designated by the Central Agency for Public Mobilization and Statistics (CAPMS)

        The law identifies these sites as “Zone A”. According to the implementing regulations, “Zone A” includes:

        • the Suez Canal Economic Zone
        • the Golden Triangle Special Economic Zone
        • the New Administrative Capital Zone
        • the south of Giza province
        • the provinces of Port Said, Ismailia and Suez (east of the canal) connected to the Suez Canal.
        • border provinces, including Red Sea province south of Safaga
        • the provinces in upper Egypt
        • other areas in greatest need of development (to be determined by the Prime Minister)

        2) Tax exemption on 30 % of the investment costs of a project located in the remaining geographical areas outside “Zone A”, referred to as “Zone B”, and operating in certain sectors.

        This includes projects that:

        • are active in the field of renewable energies
        • export their products outside Egypt
        • be carried out by a small or medium-sized (SME)

        General incentives

        Parallel to the special investment incentives, general investment incentives also apply. For example, projects are exempt from certain administrative requirements and fees for a period of 5 years from the date of their registration in the commercial register. Furthermore, temporary duty-free imports and exports are possible.

        Additional incentives

        Additional investment incentives may also be granted by decision of the Council of Ministers:

        • special customs offices for the export or import of the investment project
        • bearing of the value of the utility supply (such as electricity and water supply) of the property intended for the investment project or part thereof by the State
        • partial bearing of the costs of a technical training programme for employees by the State
        • reimbursement of half of the value of the land allocated for industrial projects, provided that the activity was started within two years of the transfer of the land
        • free allocation of land for certain strategic activities
        • under certain conditions, granting of a general permit for the construction, operation and management of the project as well as for the provision of the land required for this purpose. This permit shall also be deemed to be a building permit and shall be effective in its own right without any further action being required. In December 2022, the Egyptian Cabinet granted general approval for several projects.
        • incorporation shares of capital companies subject to the Investment Law No. 72 of 2017 may be traded during the first two fiscal years of the company, subject to the approval of the competent Minister
        • simplified acquisition of real estate, provided it is used for the project

        Takeaways

        • Egypt’s Green Hydrogen Drive: Egypt is strategically embracing green hydrogen production as a pivotal element of its renewable energy vision. The country’s ambitious goals and extensive incentives underscore its commitment to becoming a leading player in the global green energy landscape.
        • International Collaborations: Collaborations with Germany and European partners highlight Egypt’s proactive approach to international cooperation in advancing green hydrogen technologies. Memoranda of Understanding and joint roadmaps are facilitating knowledge exchange and investments for robust hydrogen projects.
        • Comprehensive Incentive Framework: Egypt’s multifaceted incentive framework, including financial subsidies, tax exemptions, and administrative benefits, showcases the government’s determination to attract investments in green hydrogen production. Stringent conditions for benefiting from these incentives emphasize the nation’s dedication to sustainable practices and local community development.

        Renata Antiquera

        Practice areas

        • Contracts
        • Corporate
        • Distribution
        • M&A
        Contact Renata

        Contact Renata





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          Vietnam | New Decree on Internet Services and Online Information

          9 December 2024

          • Vietnam
          • Foreign investments
          • Information Technology
          • Privacy - Data Protection

          Executive Summary

          The African Continental Free Trade Area (AfCFTA) remains one of the most ambitious integration projects in the world. Yet, several years into its operational phase, it has not (yet) delivered the structural shift many expected. A recent analysis underscores the gap between political momentum and economic reality: implementation remains uneven, the agreement is still used by only a portion of participating states, and non-tariff barriers and infrastructure deficits continue to dominate the cost of doing business across borders.  For Egypt, the opportunity is still real — but it depends less on treaty headlines and more on enabling conditions: trade logistics, customs efficiency, regulatory convergence, and competitive industrial capacity. 

          Looking Back: The Promise of a Single African Market

          When the AfCFTA was launched, expectations were understandably high. A continent-wide trade framework was supposed to reduce tariffs, facilitate trade in goods and services, and strengthen regional value chains — with the broader goal of moving African economies up the value ladder.

          In my 2022 article, I asked whether AfCFTA could become a game changer for Egypt, given Egypt’s industrial base, strategic geography, and the potential to diversify export markets beyond traditional partners. (For background, see the earlier article here”).

          The Reality Check: Intra-African Trade Remains Structurally Weak

          Several years later, the interim assessment is sobering. As the Frankfurter Allgemeine Zeitung (FAZ) recently put it, AfCFTA is not a “game changer” yet, and only about half of member states currently meet the practical prerequisites to trade under the agreement.

          A deeper reason is structural: no other world region trades so little with itself, and while statistics may undercount informal cross-border flows (especially in food), the overall picture remains unchanged.

          Trade integration cannot deliver transformative outcomes if production, logistics, and institutions do not support scale.

          Implementation Has Been Slow — and Often Symbolic

          Operationalisation did not start with full-scale liberalisation. Instead, the AfCFTA began with a pilot approach: the Guided Trade Initiative (GTI) launched in October 2022, initially with eight states, later joined by additional countries, including Nigeria and South Africa by spring 2025.

          The GTI created valuable learning effects, but it also underlined a key point: early progress was often presented through symbolic deals, while product coverage and volumes remained limited. FAZ highlights that only selected goods could be traded duty-free and that key sectors remained constrained for a long time due to missing or unresolved technical rules.

          A pilot, however, cannot substitute for full operational certainty — the kind businesses need to restructure supply chains and invest.

          Tariffs Are Not the Main Barrier — Trade Costs Are

          AfCFTA is frequently discussed in terms of tariff liberalisation. Yet, evidence suggests that the largest gains do not come from tariffs but from reducing non-tariff barriers and improving trade infrastructure.

          FAZ points to a central reality: tariffs tend to add around 20–30% to intra-African trade costs, whereas non-tariff costs can be far higher — driven by bureaucracy, lack of harmonised standards, inefficient border processes, and transport barriers.

          This is the crux: even with reduced tariffs, trade will not expand meaningfully if goods still cannot move cheaply, quickly, and predictably.

          Integration Complexity and Distributional Politics

          Africa’s integration landscape is shaped by multiple overlapping regional economic communities and trade regimes. This creates legal and administrative complexity — often described as an integration “spaghetti bowl.” FAZ notes the challenge of coordination and the continued fragmentation of rules.

          There is also a political economy dimension. Intra-African trade is heavily influenced by a small number of larger economies — and the distribution of benefits matters. FAZ highlights the dominance of major players (notably South Africa) and the concern that tariff liberalisation alone may entrench existing industrial advantages.

          Where governments expect asymmetric outcomes, resistance often takes the form of delay, narrow implementation, or persistent non-tariff barriers.

          What This Means for Egypt: The Opportunity Is Real — But Conditional

          Egypt’s strategic case for AfCFTA participation remains strong: industrial potential, geographic location, and the opportunity to access and shape growing markets. But the experience so far suggests that the treaty text alone does not generate trade flows.

          For Egypt’s private sector, the decisive factors are practical:

          • predictable and efficient customs clearance and border procedures,
          • logistics corridors and port efficiency,
          • regulatory convergence (standards, certification, compliance),
          • stable access to trade finance and payments,
          • competitive energy and production conditions for manufacturing and processing.

          AfCFTA can support these developments — but it cannot replace them.

          The “Game Changer” Pathway: What Must Happen Next

          FAZ concludes that AfCFTA will only become truly impactful if it is paired with the fundamentals: major infrastructure investment, stronger production and processing capacity, and a credible industrial policy.

          At the same time, Africa faces a classic chicken-and-egg problem: without development there is limited investment appeal; without investment there is limited development.

          For Egypt and its partners, a pragmatic strategy would be to:

          1. treat AfCFTA as a platform for real trade-cost reduction, not only tariff debates;
          2. focus on a limited number of scalable corridors and sectors where regional value chains can realistically grow;
          3. strengthen implementation capacity so that preferences become usable for firms — especially SMEs;
          4. enhance legal certainty and dispute resolution reliability for cross-border commerce.

          Conclusion

          AfCFTA remains a landmark achievement in terms of political commitment. But as of today, it has not yet been the “game changer” many hoped for.

          For Egypt, the key question is no longer whether AfCFTA is visionary — it is. The question is whether governments and businesses can translate it into lower real trade costs, higher competitiveness, and bankable cross-border transactions. If those enabling conditions improve, AfCFTA’s promise can still become commercial reality.

          Relocating to Spain for professional reasons is often an exciting step: a new career opportunity, a different lifestyle, and, in many cases, an improved quality of life. However, in practice, the most complex issues rarely arise from employment itself, but from the legal and tax implications surrounding housing.

          Before signing a lease or purchasing a property, it is essential to understand your administrative and tax position in Spain. A proper legal assessment at the outset can prevent costly complications later.

          Immigration Status: The Essential Starting Point

          Not all foreign nationals are in the same legal position.

          Citizens of the European Union may reside and work in Spain, but they must obtain a Foreigner Identification Number (NIE), register with the Central Register of Foreign Nationals, and register their address (empadronamiento) in the municipality where they reside.

          Non-EU nationals, on the other hand, must first secure the appropriate visa or residence and work authorization, and subsequently obtain a Foreigner Identity Card (TIE).

          This is not a mere administrative formality. Without a regularized status, practical issues may arise, including difficulties opening a bank account, setting up utilities, demonstrating financial solvency to landlords, or formalizing deeds before a notary.

          Renting in Spain: What to Review Before Signing

          Residential leases in Spain are governed by the Urban Leases Act (Ley de Arrendamientos Urbanos). Although legal residence is not technically required to sign a lease agreement, landlords often ask for additional guarantees if the tenant has recently arrived in the country.

          It is important to review carefully:

          • The agreed duration of the lease
          • Rent update mechanisms
          • Security deposit and additional guarantees
          • Early termination clauses

          Entering into a lease under time pressure, without fully understanding these terms, can result in financial obligations that may not align with the realities of an international relocation.

          Purchasing Property: Legal Access and Tax Implications

          Foreign nationals may freely acquire real estate in Spain, regardless of residency status. There are no nationality-based restrictions on ownership.

          However, property acquisition has significant tax consequences that should be assessed in advance.

          For resale properties, the Transfer Tax (Impuesto sobre Transmisiones Patrimoniales) applies, with rates varying depending on the Autonomous Community. For newly built properties, VAT (IVA) and Stamp Duty (Actos Jurídicos Documentados) are payable. Notarial and Land Registry fees must also be considered.

          The transaction must be executed through a public deed before a Spanish notary and subsequently registered at the Land Registry to ensure full legal protection against third parties.

          Tax Residency: A Determining Factor

          One of the most critical issues is whether the relocating professional becomes a tax resident in Spain.

          As a general rule, tax residence is acquired by spending more than 183 days in Spain during a calendar year or by having the primary center of economic interests located in Spain. This determination is based on objective criteria and is not dependent solely on municipal registration.

          The distinction is substantial:

          • Spanish tax residents are taxed on their worldwide income.
          • Non-residents are taxed only on income obtained in Spain, under the Non-Resident Income Tax regime.

          Even if a property is not rented, owners may be required to declare imputed income if it does not qualify as their primary residence.

          Coordination with the Country of Origin

          Relocating to Spain does not automatically eliminate tax obligations in the country of origin. Spain has signed numerous double taxation treaties, but their application requires case-by-case analysis.

          Inadequate planning may lead to dual taxation, residency conflicts, or subsequent inquiries from tax authorities in either jurisdiction.

          Plan Before You Commit

          The correct sequence does not begin with signing a lease or reserving a property. It begins with

          • clarifying immigration status
          • defining tax residence, and
          • assessing the legal and financial implications of each decision.

          Housing is not merely a real estate matter. It is a legal and economic commitment with medium- and long-term consequences.

          When a professional move involves crossing borders, careful planning is not optional. It is a fundamental step in protecting both personal stability and the success of the new professional chapter.

          New Regulatory Framework for RHQs: Tax Relief, Substantive Presence, and Streamlined Licensing

          Saudi Arabia has released the long-awaited draft of the “Rules Regulating the Licensing and Supervision of Regional Headquarters of Multinational Companies,” issued pursuant to Cabinet Resolution No. (338) dated 23/4/1445H. This regulatory framework, currently open for public consultation, forms part of the Kingdom’s ambitious Vision 2030 strategy to establish Saudi Arabia as the prime regional base for multinational enterprises (MNEs) operating in the Middle East and North Africa (MENA) region.

          Far beyond mere tax incentives, the draft Rules introduce a binding, structured regime that combines regulatory clarity with strict compliance obligations and long-term benefits. The most salient features include the following.

          30-Year Tax Holiday

          Entities licensed as RHQs will enjoy a 0% income tax rate and a 0% withholding tax rate on dividends, related-party payments, and payments for services essential to RHQ activity. These tax incentives are granted for a period of 30 years, renewable under conditions set by the Ministry of Investment.

          Operational Substance Requirements: RHQ Functions and Compliance

          At the core of the RHQ regime lies the requirement for substantial and sustained business presence in the Kingdom. Licensed RHQs must activate both mandatory and optional activities as defined in Article 7 of the Rules:

          Mandatory Activities (to be activated within the first year):

          • Preparation and implementation of the regional strategy;
          • Strategic coordination of the MNE’s operations in the region;
          • Selection of products and services offered in the region;
          • M&A support;
          • Financial performance review;
          • Budget planning for regional operations;
          • Coordination of business units across MENA;
          • Market research and competitor analysis;
          • Identification of new market opportunities;
          • Marketing strategy development;
          • Preparation of operational and financial reports.

          Optional Activities (minimum of three to be activated): These include, among others:

          • Research, development and innovation;
          • Sales and marketing;
          • Human resources and training;
          • Financial management, foreign exchange and treasury services;
          • Legal consultancy, compliance, internal audit;
          • Logistics, IP management, production, and technical support.

          The selected optional activities must be aligned with the MNE’s global business strategy and must be regionally anchored.

          Additional Substantive Requirements

          • Minimum of 15 employees in the first year;
          • At least 3 senior executives must be based in the Kingdom and must represent the top decision-making authority for the region;
          • RHQ staff must reside in Saudi Arabia, be dedicated full-time, be licensed locally, and receive remuneration through Saudi bank accounts;
          • RHQ operations must be exclusively performed within the Kingdom.

          Licensing Process and Timing

          The licensing process is clearly defined. Upon submission of the required documentation (commercial records, financials, activity plans), the Ministry of Investment will process the application within 30 working days.

          True Regional Authority and Kingdom-Centric Operations

          Licensed RHQs must hold administrative authority over all regional branches and subsidiaries. The RHQ must operate as the highest strategic, executive, and administrative authority in the MENA region. Furthermore, all RHQ-related activities must be carried out exclusively from within the Kingdom.

          Localization Requirements

          To ensure genuine local presence, the RHQ regime mandates:

          • Saudi residency and work permits for all RHQ personnel;
          • No hybrid or remote models from abroad;
          • Local registration of intellectual property and commercial identifiers;
          • Internal reporting and supervision obligations anchored in Saudi Arabia.

          Is RHQ Establishment Mandatory or Optional?

          While the RHQ license remains optional in principle, it is effectively mandatory for all multinational companies intending to contract with Saudi public sector entities.

          As of 1 January 2024, the Saudi government will only consider public procurement contracts from companies that have an RHQ presence in the Kingdom, unless an express exemption is granted. Companies operating purely in the private sector without government contracts remain unaffected, but will nonetheless benefit from the RHQ regime if they choose to participate.

          This regulatory shift creates a strategic filter: those seeking to participate in Saudi Arabia’s transformation across infrastructure, health, energy, and education must establish a fully embedded regional presence in the Kingdom.

          Conclusion: High-Reward, High-Compliance Environment

          The draft Rules represent a bold step in reshaping the MENA business landscape. Saudi Arabia is setting the bar high: generous tax relief and fast-track licensing are tied to substantive commitments in structure, personnel, and governance. For MNEs willing to assume regional leadership from within Saudi borders, the opportunity is as attractive as it is demanding.

          A dedicated notary account in Brazil is a legal mechanism that brings greater security, transparency, and reliability to financial transactions. Regulated under Law 8.935/1994 and Provision No. 197/2025, this service allows notaries to receive, manage, and release funds only after contractual conditions have been fulfilled. By ensuring segregation of assets, traceability, and impartial oversight, dedicated notary accounts provide an effective escrow-like solution for real estate deals, mergers and acquisitions, import/export operations, high-value asset purchases, and complex commercial contracts. This tool not only reduces legal risks and potential disputes but also strengthens trust between parties by guaranteeing that payments are safeguarded until obligations are met.

          The legal basis can be found in Law 8.935/1994, § 1 of art. 7-A, which allows notaries to receive, deposit, and manage amounts related to legal transactions, with transactions subject to objectively verifiable facts/conditions. Provision No. 197, dated June 13, 2025, regulates, at the national level, the service of notarial accounts linked to Notary Public Offices.

          Practical applications: among others, in the following transactions:

          • Real estate: guarantee that the down payment and settlement amounts will be secured in a specific account. This mitigates the risk of misappropriation of funds and ensures that the money will be released only after all contractual conditions have been met.
          • M&A: the linked notarial account creates a standardized escrow mechanism for the payment of price/holdbacks/earn-outs and conditional obligations.
          • Purchase and Sale of High-Value Movable Property: the linked account can be used to guarantee payment. The buyer deposits the amount and the seller knows that the money is safe, being released only after the transfer of ownership and delivery of the goods.
          • Import and Export: the transaction amount can be deposited with the notary and released to the exporter only after confirmation of delivery of the goods in the destination country, for example.
          • Guarantee of Obligations: In any contract that provides for the payment of a sum of money as a guarantee, the notary account can be used to provide greater security to the parties.
          • Supply, EPC/turnkey, and construction contracts: performance retentions, milestone acceptance (commissioning, as-built, issuance of ART/CREA), and payment against formal acceptance.
          • Contractual joint ventures and commercial partnerships: advances conditional on licenses, authorizations, or competitive approval, where applicable.

          Reduction of Legal Risks: The use of linked accounts reduces the chances of litigation related to lack of clarity about the origin and destination of funds. Companies can clearly demonstrate that payments were made and held by an impartial and secure institution.

          Operational structure: limited to banking entities affiliated with the CNB, which must ensure the segregation of assets, traceability through audit trails, and proof of all transactions. The authorization of the delegate requires prior accreditation and electronic registration of the essential details of the transaction and its conditions in the CNB system, with access restricted to the parties and the notary.

          Specific Purpose: amounts received as payment, guarantee, or advance payment as a result of notarial acts must be deposited in a bank account linked to the specific act and may only be moved for the purpose for which they are intended.

          Transparency and Traceability: With the linked notarial account, it is possible to clearly track the financial flow of each transaction, which increases transparency for all parties and for supervisory bodies.

          Verification of conditions and release. Once the objective conditions have been met, the notary authorizes the transfer to the recipients and files the proof of verification. In the event of a dispute between the parties, the notary suspends any movement, draws up a notarial deed, and advises on a consensual or judicial solution, without deciding on the effectiveness/termination of the transaction; if the transaction is frustrated and no solution is found, the procedure is terminated and the amounts are returned to the depositor, in accordance with the agreed clauses.

          Confidentiality and access. In transactions with a confidentiality clause, the notary public maintains confidentiality and does not issue certificates regarding the content of the transaction; documents are accessible only for correctional purposes or by court order.

          Remuneration and costs. The notary’s remuneration for the notarial account service is paid by the financial institution under the terms of the agreement, and the transfer of additional costs to the user is prohibited, without prejudice to fees for any related notarial acts.

          The Government of Vietnam has issued a new decree governing internet services and online information, which shall come into force on 25 December 2024. Decree No. 147/2024/ND-CP, promulgated on 9 November 2024, supersedes the previous Decree No. 72/2013/ND-CP and its amendments.

          This comprehensive legislation, comprising over 200 pages and 62 appended forms, addresses a wide array of internet and online topics. These include inter alia, internet services, domain names, cross-border information provision, social network services, aggregated information websites, online game services, and app store services.

          Key Provisions

          Cross-Border Information Provision

          Offshore service providers, including those offering social network and app store services on a cross-border basis, are subject to stricter requirements if they either lease data storage in Vietnam or meet a threshold of 100,000 or more total visits per month from Vietnam for six consecutive months. These providers must:

          1. Notify the Authority of Broadcasting and Electronic Information (ABEI) of their contact information
          2. Monitor and remove illegal content
          3. Store and manage user data as required
          4. Authenticate social network user accounts using Vietnamese mobile numbers or identification numbers
          5. Submit annual and ad hoc reports to the ABEI
          6. Handle user complaints

          Only cross-border providers who have notified the ABEI of their contact details may offer live stream and revenue-generating services. Non-compliance may result in blocks and penalties.

          Social Networks

          Decree 147 establishes distinct regimes for offshore and onshore social network services:

          1. Offshore providers meeting the aforementioned threshold must notify the ABEI of their contact information.
          2. Onshore providers reaching 10,000 total visits per month for six consecutive months or 1,000 regular users per month must obtain a Social Network Licence.
          3. Other onshore providers with low traffic must obtain a Notification Certificate from the ABEI.

          The decree also regulates livestream activities by stipulating conditions for social network service providers to offer livestream functions and for social network accounts to conduct livestream activities.

          Online Games

          Foreign organisations and individuals are prohibited from providing online games to service users in Vietnam on a cross-border basis. To offer such services, they must establish a local enterprise in Vietnam.

          This new decree is expected to have a significant impact on both onshore and offshore service providers in the respective fields and may tighten the regulatory landscape for internet services and online information provision in Vietnam.

          “This agreement is not just an economic opportunity. It is a political necessity.” In the current geopolitical context of growing protectionism and significant regional conflicts, Ursula von der Leyen’s statement says a lot.

          Even though there is still a long way to go before the agreement is approved internally in each bloc and comes into force, the milestone is highly significant. It took 25 years from the start of negotiations between Mercosur and the European Union to reach a consensus text. The impacts will be considerable. Together, the blocs represent a GDP of over 22 trillion dollars, and are home to over 700 million people.

          Our aim here is to highlight, in a simplified manner, the most important information about the agreement’s content and its progress, which we will update here at each stage.

          What is it?

          The agreement was signed as a trade treaty, with the main goal of reducing import and export tariffs, eliminating bureaucratic barriers, and facilitating trade between Mercosur countries and European Union members. Additionally, the pact includes commitments in areas such as sustainability, labor rights, technological cooperation, and environmental protection.

          Mercosur (Southern Common Market) is an economic bloc created in 1991 by Brazil, Argentina, Paraguay, and Uruguay. Now, Bolivia and Chile participate as associated members, accessing some trade agreements, but not fully integrated into the common market. On the other hand, the European Union, with its 27 members (20 of which have adopted the common currency), is a broader union with greater economic and social integration compared to Mercosur.

          What does the EU Mercosur agreement include?

          Trade in goods:

          • Reduction or elimination of tariffs on products traded between the blocs, such as meat, grains, fruits, automobiles, wines, and dairy products (the expected reduction will affect over 90% of the traded goods between the blocks).
          • Easier access to European high-tech and industrialized products.

          Trade in services:

          • Expands access to financial services, telecommunications, transportation, and consulting for businesses in both blocs.

          Movement of people:

          • Provides facilities for temporary visas for qualified workers, such as technology professionals and engineers, promoting talent exchange.
          • Encourages educational and cultural cooperation programs.

          Sustainability and environment:

          • Includes commitments to combat deforestation and meet the goals of the Paris Agreement on climate change.
          • Provides penalties for violations of environmental standards.

          Intellectual property and regulations:

          • Protects geographical indications for European cheese, wines, and South American coffee and cachaça.
          • Harmonizes regulatory standards to reduce bureaucracy and avoid technical barriers.

          Labor rights:

          • Commitment to decent working conditions and compliance with International Labor Organization (ILO) standards.

          Which benefits to expect?

          • Access to new markets: Mercosur companies will have easier access to the European market, which has more than 450 million consumers, while European products will become more competitive in South America.
          • Costs reduction: The elimination or reduction of tariffs could lower the prices of products such as wines, cheese, and automobiles and boost South American exports of meat, grains, and fruits.
          • Strengthened diplomatic relations: The agreement symbolizes a bridge of cooperation between two regions historically connected by cultural and economic ties.

          What’s next?

          The signing is only the first step. For the agreement to come into force, it must be ratified by both blocs, and the approval process is quite distinct between them, since Mercosur does not have a common Council or Parliament.

          In the European Union, the ratification process involves multiple institutional steps:

          • Council of the European Union: Ministers from the member states will discuss and approve the text of the agreement. This step is crucial, as each country has representation and may raise specific national concerns.
          • European Parliament: After approval by the Council, the European Parliament, composed of elected deputies, votes to ratify the agreement. The debate at this stage may include environmental, social, and economic impacts.
          • National Parliaments: In cases where the agreement affects shared competencies between the bloc and member states (such as environmental regulations), it must also be approved by the parliaments of each member country. This can be challenging, given that countries like France and Ireland have already expressed specific concerns about agricultural and environmental issues.

          In Mercosur, the approval depends on each member country:

          • National Congresses: The agreement text is submitted to the parliaments of Brazil, Argentina, Paraguay, and Uruguay. Each congress evaluates independently, and approval depends on the political majority in each country.
          • Political Context: Mercosur countries have diverse political realities. In Brazil, for example, environmental issues can spark heated debates, while in Argentina, the impact on agricultural competitiveness may be the focus of discussion.
          • Regional Coordination: Even after national approval, it is necessary to ensure that all Mercosur members ratify the agreement, as the bloc acts as a single negotiating entity.

          Stay tuned: you will find the update here as the processes advance.

          Vietnam has embraced the global minimum tax (GMT) to harmonize its tax policies with global standards. While this new tax regime is anticipated to have certain adverse effects on foreign direct investment (FDI), the Vietnamese government is devising proactive measures to mitigate these repercussions and maintain the country’s appeal as an investment haven.

          Key Ramifications of the GMT for Vietnam

          The GMT mandates multinational corporations (MNCs) with consolidated revenue surpassing €750 million to pay a minimum tax rate of 15%, irrespective of the tax rate in the country where they operate. In Vietnam, this translates to the concept of a qualified domestic minimum top-up tax (QDMTT).

          The QDMTT places an extra tax burden on foreign-invested enterprises (FIEs) that are part of an MNC, potentially deterring them from investing or expanding in Vietnam. This is particularly concerning for industries that heavily rely on tax incentives to attract FDI.

          Vietnam’s Response: Investment Support Fund and Proactive Measures

          In response to the anticipated negative impacts of the GMT, the Vietnamese government has established an investment support fund (Fund) to incentivize investments in targeted sectors. The Fund is primarily funded by proceeds from the State Budget generated by the GMT.

          Eligible enterprises for the Fund are those engaged in high-tech product manufacturing, high-tech enterprises, high-tech application projects, and enterprises with investment projects in research and development centers. Eligibility is based on capital size, annual revenue, industry, or technology utilized.

          Eligible taxpayers can receive cash subsidies for five specific expense categories:

          1. Human resource training and development
          2. Research and development expenses
          3. Fixed asset investments
          4. High-tech manufacturing expenses
          5. Social infrastructure systems

          To qualify for Fund benefits, eligible taxpayers must submit an application dossier to the Fund Office in Hanoi between August 15th and 30th of the year following the incurred Supported Expenses. Each Supported Expense category will have a distinct reimbursement ratio, and support payments will be contingent on the actual expenses incurred by eligible taxpayers.

          In addition to the Fund, the Vietnamese government is also implementing proactive measures to address the concerns of foreign investors. These measures include:

          1. Focusing on targeted industries with high growth potential that align with Vietnam’s strategic development goals
          2. Utilizing the additional revenue collected from top-up tax to enhance infrastructure and labor quality
          3. Considering cash grants for long-term qualified investments in high-tech industries

          Conclusion

          The introduction of the GMT poses challenges for Vietnam in attracting FDI. However, the government’s establishment of the investment support fund and proactive measures demonstrates its commitment to safeguarding the country’s competitiveness as an investment destination. By combining targeted support with infrastructure improvements and incentives for specific industries, Vietnam can mitigate the negative impacts of the GMT and continue to attract foreign investors.

          Summary

          Egypt aims to be Africa’s first green hydrogen producer by incentivizing companies to invest in the sector. Collaborative efforts with Germany and European companies are underway to enhance hydrogen projects and transport. Incentives include financial subsidies, tax exemptions, and administrative advantages, contingent on project conditions like commissioning, foreign funding, local materials use, and community development.

          What is the status of green energy in Egypt and what role does green hydrogen play in this?

          It is currently estimated that Egypt has the potential to generate 350 GW of wind energy and about 650 GW of solar energy per year, as per the Minister of Electricity and Renewable Energy’s (Mohamed Shaker El-Marqabi) declaration. As part of its National Climate Strategy 2050, Egypt has set itself the goal of reducing its carbon emissions, promoting the use of renewable energy sources and using alternative forms of energy, including green hydrogen. The importance the Egyptian government attaches to green hydrogen is evident, not least with the recent cabinet meeting on 17th of May 2023.

          With a view to becoming the first African country to produce green hydrogen, new incentives for green hydrogen and derivatives projects were presented at the cabinet meeting. Based on an investment of 13 billion USD, the legal and financial benefits (new incentive package) that companies in this field can benefit from in the future were presented.

          What agreements exist between Egypt and third countries to promote green hydrogen?

          Agreement between Egypt and Germany on green hydrogen

          The new incentive package was preceded by a meeting between the German-Egyptian Partnership for Green Hydrogen Projects committee and Egyptian officials on the 14th of March 2023. This resulted in a joint roadmap for supporting hydrogen production companies and promoting hydrogen transport and marketing. At this meeting, it was decided that the parties, the Egyptian Minister of International Cooperation (Rania Al-Mashat) and the Egyptian Minister of Public Enterprises (Mahmoud Esmat), will establish a platform to promote the use of green hydrogen.

          At the above-mentioned meeting, Egypt and Germany signed two Memoranda of Understanding (MoU) to enhance cooperation in the field of green hydrogen.

          The Egyptian Government also recently signed other MoUs with seven European leading companies and global alliances to produce new and renewable energy, to establish green hydrogen production complexes in Ain Al-Sokhna and the Red Sea Governorate.

          The German-Egyptian cooperation in the field of green hydrogen follows Egypt’s goal to establish itself as a hub for producing green hydrogen.

          Agreement between Egypt and third countries on green hydrogen

          Egypt has also partnered with the European Union to advance green hydrogen production. Furthermore, in 2022, on the occasion of COP27, Egypt signed a series of MoUs with several international organisations to engage foreign investment in green hydrogen production and make Egypt a transit route for clean energy to Europe.

          MoUs with global companies and alliances have defined the Red Sea Governorate as the location where green hydrogen projects will be carried out in the future.

          Are there investment incentives for the production of green hydrogen in Egypt?

          In the cabinet meeting of 17th of May 2023, the Egyptian Prime Minister Mustafa Madbuli stated that Egypt was offering the “largest” package of investment incentives and facilitations to companies wishing to invest in green hydrogen production projects in Egypt. He further announced the formation of a working group composed of representatives of the authorities involved to elaborate these investment incentives.

          The statement indicated that companies involved in green energy projects in Egypt will benefit from incentives set out in the Law drafted in the cabinet meeting of 17th of May 2023 and Investment Law No. 72 of 2017. This targets companies involved in the “production, storage and export of green hydrogen”.

          What investment incentives for the production of green hydrogen in Egypt are provided for in the draft Law of 17th of May 2023?

          Financial incentives

          Investments in the green hydrogen sector are subsidised in the amount of 33 % to 55 % of the income tax payable. The Ministry of Finance pays the subsidy within 45 days after the deadline for filing the tax return. The subsidy itself is not taxable. The exact conditions for the payment of the subsidy are still to be determined by the Cabinet.

          All machinery, equipment, materials, consumables and vehicles (except private vehicles) used in green hydrogen and derivative projects are exempt from VAT.

          No VAT is levied on exports of green hydrogen and its derivatives.

          The Ministry of Finance pays most of the duties and certification costs associated with setting up the business and all import duties on imported goods used by the establishment. Further, it pays the taxes that would have been levied on the real estate used for the activity, if any.

          Administrative incentives

          Projects in the field of green hydrogen or its derivatives benefit from the so-called golden licence, as it is called in the Investment Law No. 72 of 2017.

          All raw materials, spare parts and vehicles required for operations can be freely imported or exported directly or through distributors without the need for registration in the Importers’ Register.

          The incentives apply to projects and their extensions throughout the contract period if the project agreements are concluded within a maximum of 7 years from the date of commercial commissioning.

          Requirements

          The investment incentives apply when:

          • the project is commissioned within 5 years of the signing of the project agreement
          • at least 70 % of the investment costs come from foreign funds
          • at least 20 % of the locally used materials originate from Egypt
          • training programmes are set up for local workers and know-how is shared
          • the project company draws up a development plan for the communities in which it will operate

          What investment incentives for the production of green hydrogen in Egypt are provided for in the Investment Law No. 72 of 2017?

          The tax incentives granted under the Investment Law No. 72 of 2017 provide for special, general and additional incentives.

          Special incentives

          These are tax reductions limited to 7 years for projects that are started within 3 years (extendable to 6 years) after the provisions of the Law No. 72 of 2017 came into force (i.e. by October 2023). The investment costs consist of equity capital, long-term loans to finance the construction of the project’s movable and immovable assets, and working capital. The tax base is the taxable net profit, which is taxed at the following rates:

          1) Tax exemption on 50 % of the investment costs for the implementation of a project in geographical locations with the greatest development needs (underdeveloped locations) designated by the Central Agency for Public Mobilization and Statistics (CAPMS)

          The law identifies these sites as “Zone A”. According to the implementing regulations, “Zone A” includes:

          • the Suez Canal Economic Zone
          • the Golden Triangle Special Economic Zone
          • the New Administrative Capital Zone
          • the south of Giza province
          • the provinces of Port Said, Ismailia and Suez (east of the canal) connected to the Suez Canal.
          • border provinces, including Red Sea province south of Safaga
          • the provinces in upper Egypt
          • other areas in greatest need of development (to be determined by the Prime Minister)

          2) Tax exemption on 30 % of the investment costs of a project located in the remaining geographical areas outside “Zone A”, referred to as “Zone B”, and operating in certain sectors.

          This includes projects that:

          • are active in the field of renewable energies
          • export their products outside Egypt
          • be carried out by a small or medium-sized (SME)

          General incentives

          Parallel to the special investment incentives, general investment incentives also apply. For example, projects are exempt from certain administrative requirements and fees for a period of 5 years from the date of their registration in the commercial register. Furthermore, temporary duty-free imports and exports are possible.

          Additional incentives

          Additional investment incentives may also be granted by decision of the Council of Ministers:

          • special customs offices for the export or import of the investment project
          • bearing of the value of the utility supply (such as electricity and water supply) of the property intended for the investment project or part thereof by the State
          • partial bearing of the costs of a technical training programme for employees by the State
          • reimbursement of half of the value of the land allocated for industrial projects, provided that the activity was started within two years of the transfer of the land
          • free allocation of land for certain strategic activities
          • under certain conditions, granting of a general permit for the construction, operation and management of the project as well as for the provision of the land required for this purpose. This permit shall also be deemed to be a building permit and shall be effective in its own right without any further action being required. In December 2022, the Egyptian Cabinet granted general approval for several projects.
          • incorporation shares of capital companies subject to the Investment Law No. 72 of 2017 may be traded during the first two fiscal years of the company, subject to the approval of the competent Minister
          • simplified acquisition of real estate, provided it is used for the project

          Takeaways

          • Egypt’s Green Hydrogen Drive: Egypt is strategically embracing green hydrogen production as a pivotal element of its renewable energy vision. The country’s ambitious goals and extensive incentives underscore its commitment to becoming a leading player in the global green energy landscape.
          • International Collaborations: Collaborations with Germany and European partners highlight Egypt’s proactive approach to international cooperation in advancing green hydrogen technologies. Memoranda of Understanding and joint roadmaps are facilitating knowledge exchange and investments for robust hydrogen projects.
          • Comprehensive Incentive Framework: Egypt’s multifaceted incentive framework, including financial subsidies, tax exemptions, and administrative benefits, showcases the government’s determination to attract investments in green hydrogen production. Stringent conditions for benefiting from these incentives emphasize the nation’s dedication to sustainable practices and local community development.

          Federico Vasoli

          Practice areas

          • Corporate
          • Foreign investments
          • M&A
          Contact Federico

          Contact Federico





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            The Milestone EU-Mercosur Trade Deal

            9 December 2024

            • Argentina
            • Brazil
            • Italy
            • Uruguay
            • Distribution
            • Foreign investments
            • Tax

            Executive Summary

            The African Continental Free Trade Area (AfCFTA) remains one of the most ambitious integration projects in the world. Yet, several years into its operational phase, it has not (yet) delivered the structural shift many expected. A recent analysis underscores the gap between political momentum and economic reality: implementation remains uneven, the agreement is still used by only a portion of participating states, and non-tariff barriers and infrastructure deficits continue to dominate the cost of doing business across borders.  For Egypt, the opportunity is still real — but it depends less on treaty headlines and more on enabling conditions: trade logistics, customs efficiency, regulatory convergence, and competitive industrial capacity. 

            Looking Back: The Promise of a Single African Market

            When the AfCFTA was launched, expectations were understandably high. A continent-wide trade framework was supposed to reduce tariffs, facilitate trade in goods and services, and strengthen regional value chains — with the broader goal of moving African economies up the value ladder.

            In my 2022 article, I asked whether AfCFTA could become a game changer for Egypt, given Egypt’s industrial base, strategic geography, and the potential to diversify export markets beyond traditional partners. (For background, see the earlier article here”).

            The Reality Check: Intra-African Trade Remains Structurally Weak

            Several years later, the interim assessment is sobering. As the Frankfurter Allgemeine Zeitung (FAZ) recently put it, AfCFTA is not a “game changer” yet, and only about half of member states currently meet the practical prerequisites to trade under the agreement.

            A deeper reason is structural: no other world region trades so little with itself, and while statistics may undercount informal cross-border flows (especially in food), the overall picture remains unchanged.

            Trade integration cannot deliver transformative outcomes if production, logistics, and institutions do not support scale.

            Implementation Has Been Slow — and Often Symbolic

            Operationalisation did not start with full-scale liberalisation. Instead, the AfCFTA began with a pilot approach: the Guided Trade Initiative (GTI) launched in October 2022, initially with eight states, later joined by additional countries, including Nigeria and South Africa by spring 2025.

            The GTI created valuable learning effects, but it also underlined a key point: early progress was often presented through symbolic deals, while product coverage and volumes remained limited. FAZ highlights that only selected goods could be traded duty-free and that key sectors remained constrained for a long time due to missing or unresolved technical rules.

            A pilot, however, cannot substitute for full operational certainty — the kind businesses need to restructure supply chains and invest.

            Tariffs Are Not the Main Barrier — Trade Costs Are

            AfCFTA is frequently discussed in terms of tariff liberalisation. Yet, evidence suggests that the largest gains do not come from tariffs but from reducing non-tariff barriers and improving trade infrastructure.

            FAZ points to a central reality: tariffs tend to add around 20–30% to intra-African trade costs, whereas non-tariff costs can be far higher — driven by bureaucracy, lack of harmonised standards, inefficient border processes, and transport barriers.

            This is the crux: even with reduced tariffs, trade will not expand meaningfully if goods still cannot move cheaply, quickly, and predictably.

            Integration Complexity and Distributional Politics

            Africa’s integration landscape is shaped by multiple overlapping regional economic communities and trade regimes. This creates legal and administrative complexity — often described as an integration “spaghetti bowl.” FAZ notes the challenge of coordination and the continued fragmentation of rules.

            There is also a political economy dimension. Intra-African trade is heavily influenced by a small number of larger economies — and the distribution of benefits matters. FAZ highlights the dominance of major players (notably South Africa) and the concern that tariff liberalisation alone may entrench existing industrial advantages.

            Where governments expect asymmetric outcomes, resistance often takes the form of delay, narrow implementation, or persistent non-tariff barriers.

            What This Means for Egypt: The Opportunity Is Real — But Conditional

            Egypt’s strategic case for AfCFTA participation remains strong: industrial potential, geographic location, and the opportunity to access and shape growing markets. But the experience so far suggests that the treaty text alone does not generate trade flows.

            For Egypt’s private sector, the decisive factors are practical:

            • predictable and efficient customs clearance and border procedures,
            • logistics corridors and port efficiency,
            • regulatory convergence (standards, certification, compliance),
            • stable access to trade finance and payments,
            • competitive energy and production conditions for manufacturing and processing.

            AfCFTA can support these developments — but it cannot replace them.

            The “Game Changer” Pathway: What Must Happen Next

            FAZ concludes that AfCFTA will only become truly impactful if it is paired with the fundamentals: major infrastructure investment, stronger production and processing capacity, and a credible industrial policy.

            At the same time, Africa faces a classic chicken-and-egg problem: without development there is limited investment appeal; without investment there is limited development.

            For Egypt and its partners, a pragmatic strategy would be to:

            1. treat AfCFTA as a platform for real trade-cost reduction, not only tariff debates;
            2. focus on a limited number of scalable corridors and sectors where regional value chains can realistically grow;
            3. strengthen implementation capacity so that preferences become usable for firms — especially SMEs;
            4. enhance legal certainty and dispute resolution reliability for cross-border commerce.

            Conclusion

            AfCFTA remains a landmark achievement in terms of political commitment. But as of today, it has not yet been the “game changer” many hoped for.

            For Egypt, the key question is no longer whether AfCFTA is visionary — it is. The question is whether governments and businesses can translate it into lower real trade costs, higher competitiveness, and bankable cross-border transactions. If those enabling conditions improve, AfCFTA’s promise can still become commercial reality.

            Relocating to Spain for professional reasons is often an exciting step: a new career opportunity, a different lifestyle, and, in many cases, an improved quality of life. However, in practice, the most complex issues rarely arise from employment itself, but from the legal and tax implications surrounding housing.

            Before signing a lease or purchasing a property, it is essential to understand your administrative and tax position in Spain. A proper legal assessment at the outset can prevent costly complications later.

            Immigration Status: The Essential Starting Point

            Not all foreign nationals are in the same legal position.

            Citizens of the European Union may reside and work in Spain, but they must obtain a Foreigner Identification Number (NIE), register with the Central Register of Foreign Nationals, and register their address (empadronamiento) in the municipality where they reside.

            Non-EU nationals, on the other hand, must first secure the appropriate visa or residence and work authorization, and subsequently obtain a Foreigner Identity Card (TIE).

            This is not a mere administrative formality. Without a regularized status, practical issues may arise, including difficulties opening a bank account, setting up utilities, demonstrating financial solvency to landlords, or formalizing deeds before a notary.

            Renting in Spain: What to Review Before Signing

            Residential leases in Spain are governed by the Urban Leases Act (Ley de Arrendamientos Urbanos). Although legal residence is not technically required to sign a lease agreement, landlords often ask for additional guarantees if the tenant has recently arrived in the country.

            It is important to review carefully:

            • The agreed duration of the lease
            • Rent update mechanisms
            • Security deposit and additional guarantees
            • Early termination clauses

            Entering into a lease under time pressure, without fully understanding these terms, can result in financial obligations that may not align with the realities of an international relocation.

            Purchasing Property: Legal Access and Tax Implications

            Foreign nationals may freely acquire real estate in Spain, regardless of residency status. There are no nationality-based restrictions on ownership.

            However, property acquisition has significant tax consequences that should be assessed in advance.

            For resale properties, the Transfer Tax (Impuesto sobre Transmisiones Patrimoniales) applies, with rates varying depending on the Autonomous Community. For newly built properties, VAT (IVA) and Stamp Duty (Actos Jurídicos Documentados) are payable. Notarial and Land Registry fees must also be considered.

            The transaction must be executed through a public deed before a Spanish notary and subsequently registered at the Land Registry to ensure full legal protection against third parties.

            Tax Residency: A Determining Factor

            One of the most critical issues is whether the relocating professional becomes a tax resident in Spain.

            As a general rule, tax residence is acquired by spending more than 183 days in Spain during a calendar year or by having the primary center of economic interests located in Spain. This determination is based on objective criteria and is not dependent solely on municipal registration.

            The distinction is substantial:

            • Spanish tax residents are taxed on their worldwide income.
            • Non-residents are taxed only on income obtained in Spain, under the Non-Resident Income Tax regime.

            Even if a property is not rented, owners may be required to declare imputed income if it does not qualify as their primary residence.

            Coordination with the Country of Origin

            Relocating to Spain does not automatically eliminate tax obligations in the country of origin. Spain has signed numerous double taxation treaties, but their application requires case-by-case analysis.

            Inadequate planning may lead to dual taxation, residency conflicts, or subsequent inquiries from tax authorities in either jurisdiction.

            Plan Before You Commit

            The correct sequence does not begin with signing a lease or reserving a property. It begins with

            • clarifying immigration status
            • defining tax residence, and
            • assessing the legal and financial implications of each decision.

            Housing is not merely a real estate matter. It is a legal and economic commitment with medium- and long-term consequences.

            When a professional move involves crossing borders, careful planning is not optional. It is a fundamental step in protecting both personal stability and the success of the new professional chapter.

            New Regulatory Framework for RHQs: Tax Relief, Substantive Presence, and Streamlined Licensing

            Saudi Arabia has released the long-awaited draft of the “Rules Regulating the Licensing and Supervision of Regional Headquarters of Multinational Companies,” issued pursuant to Cabinet Resolution No. (338) dated 23/4/1445H. This regulatory framework, currently open for public consultation, forms part of the Kingdom’s ambitious Vision 2030 strategy to establish Saudi Arabia as the prime regional base for multinational enterprises (MNEs) operating in the Middle East and North Africa (MENA) region.

            Far beyond mere tax incentives, the draft Rules introduce a binding, structured regime that combines regulatory clarity with strict compliance obligations and long-term benefits. The most salient features include the following.

            30-Year Tax Holiday

            Entities licensed as RHQs will enjoy a 0% income tax rate and a 0% withholding tax rate on dividends, related-party payments, and payments for services essential to RHQ activity. These tax incentives are granted for a period of 30 years, renewable under conditions set by the Ministry of Investment.

            Operational Substance Requirements: RHQ Functions and Compliance

            At the core of the RHQ regime lies the requirement for substantial and sustained business presence in the Kingdom. Licensed RHQs must activate both mandatory and optional activities as defined in Article 7 of the Rules:

            Mandatory Activities (to be activated within the first year):

            • Preparation and implementation of the regional strategy;
            • Strategic coordination of the MNE’s operations in the region;
            • Selection of products and services offered in the region;
            • M&A support;
            • Financial performance review;
            • Budget planning for regional operations;
            • Coordination of business units across MENA;
            • Market research and competitor analysis;
            • Identification of new market opportunities;
            • Marketing strategy development;
            • Preparation of operational and financial reports.

            Optional Activities (minimum of three to be activated): These include, among others:

            • Research, development and innovation;
            • Sales and marketing;
            • Human resources and training;
            • Financial management, foreign exchange and treasury services;
            • Legal consultancy, compliance, internal audit;
            • Logistics, IP management, production, and technical support.

            The selected optional activities must be aligned with the MNE’s global business strategy and must be regionally anchored.

            Additional Substantive Requirements

            • Minimum of 15 employees in the first year;
            • At least 3 senior executives must be based in the Kingdom and must represent the top decision-making authority for the region;
            • RHQ staff must reside in Saudi Arabia, be dedicated full-time, be licensed locally, and receive remuneration through Saudi bank accounts;
            • RHQ operations must be exclusively performed within the Kingdom.

            Licensing Process and Timing

            The licensing process is clearly defined. Upon submission of the required documentation (commercial records, financials, activity plans), the Ministry of Investment will process the application within 30 working days.

            True Regional Authority and Kingdom-Centric Operations

            Licensed RHQs must hold administrative authority over all regional branches and subsidiaries. The RHQ must operate as the highest strategic, executive, and administrative authority in the MENA region. Furthermore, all RHQ-related activities must be carried out exclusively from within the Kingdom.

            Localization Requirements

            To ensure genuine local presence, the RHQ regime mandates:

            • Saudi residency and work permits for all RHQ personnel;
            • No hybrid or remote models from abroad;
            • Local registration of intellectual property and commercial identifiers;
            • Internal reporting and supervision obligations anchored in Saudi Arabia.

            Is RHQ Establishment Mandatory or Optional?

            While the RHQ license remains optional in principle, it is effectively mandatory for all multinational companies intending to contract with Saudi public sector entities.

            As of 1 January 2024, the Saudi government will only consider public procurement contracts from companies that have an RHQ presence in the Kingdom, unless an express exemption is granted. Companies operating purely in the private sector without government contracts remain unaffected, but will nonetheless benefit from the RHQ regime if they choose to participate.

            This regulatory shift creates a strategic filter: those seeking to participate in Saudi Arabia’s transformation across infrastructure, health, energy, and education must establish a fully embedded regional presence in the Kingdom.

            Conclusion: High-Reward, High-Compliance Environment

            The draft Rules represent a bold step in reshaping the MENA business landscape. Saudi Arabia is setting the bar high: generous tax relief and fast-track licensing are tied to substantive commitments in structure, personnel, and governance. For MNEs willing to assume regional leadership from within Saudi borders, the opportunity is as attractive as it is demanding.

            A dedicated notary account in Brazil is a legal mechanism that brings greater security, transparency, and reliability to financial transactions. Regulated under Law 8.935/1994 and Provision No. 197/2025, this service allows notaries to receive, manage, and release funds only after contractual conditions have been fulfilled. By ensuring segregation of assets, traceability, and impartial oversight, dedicated notary accounts provide an effective escrow-like solution for real estate deals, mergers and acquisitions, import/export operations, high-value asset purchases, and complex commercial contracts. This tool not only reduces legal risks and potential disputes but also strengthens trust between parties by guaranteeing that payments are safeguarded until obligations are met.

            The legal basis can be found in Law 8.935/1994, § 1 of art. 7-A, which allows notaries to receive, deposit, and manage amounts related to legal transactions, with transactions subject to objectively verifiable facts/conditions. Provision No. 197, dated June 13, 2025, regulates, at the national level, the service of notarial accounts linked to Notary Public Offices.

            Practical applications: among others, in the following transactions:

            • Real estate: guarantee that the down payment and settlement amounts will be secured in a specific account. This mitigates the risk of misappropriation of funds and ensures that the money will be released only after all contractual conditions have been met.
            • M&A: the linked notarial account creates a standardized escrow mechanism for the payment of price/holdbacks/earn-outs and conditional obligations.
            • Purchase and Sale of High-Value Movable Property: the linked account can be used to guarantee payment. The buyer deposits the amount and the seller knows that the money is safe, being released only after the transfer of ownership and delivery of the goods.
            • Import and Export: the transaction amount can be deposited with the notary and released to the exporter only after confirmation of delivery of the goods in the destination country, for example.
            • Guarantee of Obligations: In any contract that provides for the payment of a sum of money as a guarantee, the notary account can be used to provide greater security to the parties.
            • Supply, EPC/turnkey, and construction contracts: performance retentions, milestone acceptance (commissioning, as-built, issuance of ART/CREA), and payment against formal acceptance.
            • Contractual joint ventures and commercial partnerships: advances conditional on licenses, authorizations, or competitive approval, where applicable.

            Reduction of Legal Risks: The use of linked accounts reduces the chances of litigation related to lack of clarity about the origin and destination of funds. Companies can clearly demonstrate that payments were made and held by an impartial and secure institution.

            Operational structure: limited to banking entities affiliated with the CNB, which must ensure the segregation of assets, traceability through audit trails, and proof of all transactions. The authorization of the delegate requires prior accreditation and electronic registration of the essential details of the transaction and its conditions in the CNB system, with access restricted to the parties and the notary.

            Specific Purpose: amounts received as payment, guarantee, or advance payment as a result of notarial acts must be deposited in a bank account linked to the specific act and may only be moved for the purpose for which they are intended.

            Transparency and Traceability: With the linked notarial account, it is possible to clearly track the financial flow of each transaction, which increases transparency for all parties and for supervisory bodies.

            Verification of conditions and release. Once the objective conditions have been met, the notary authorizes the transfer to the recipients and files the proof of verification. In the event of a dispute between the parties, the notary suspends any movement, draws up a notarial deed, and advises on a consensual or judicial solution, without deciding on the effectiveness/termination of the transaction; if the transaction is frustrated and no solution is found, the procedure is terminated and the amounts are returned to the depositor, in accordance with the agreed clauses.

            Confidentiality and access. In transactions with a confidentiality clause, the notary public maintains confidentiality and does not issue certificates regarding the content of the transaction; documents are accessible only for correctional purposes or by court order.

            Remuneration and costs. The notary’s remuneration for the notarial account service is paid by the financial institution under the terms of the agreement, and the transfer of additional costs to the user is prohibited, without prejudice to fees for any related notarial acts.

            The Government of Vietnam has issued a new decree governing internet services and online information, which shall come into force on 25 December 2024. Decree No. 147/2024/ND-CP, promulgated on 9 November 2024, supersedes the previous Decree No. 72/2013/ND-CP and its amendments.

            This comprehensive legislation, comprising over 200 pages and 62 appended forms, addresses a wide array of internet and online topics. These include inter alia, internet services, domain names, cross-border information provision, social network services, aggregated information websites, online game services, and app store services.

            Key Provisions

            Cross-Border Information Provision

            Offshore service providers, including those offering social network and app store services on a cross-border basis, are subject to stricter requirements if they either lease data storage in Vietnam or meet a threshold of 100,000 or more total visits per month from Vietnam for six consecutive months. These providers must:

            1. Notify the Authority of Broadcasting and Electronic Information (ABEI) of their contact information
            2. Monitor and remove illegal content
            3. Store and manage user data as required
            4. Authenticate social network user accounts using Vietnamese mobile numbers or identification numbers
            5. Submit annual and ad hoc reports to the ABEI
            6. Handle user complaints

            Only cross-border providers who have notified the ABEI of their contact details may offer live stream and revenue-generating services. Non-compliance may result in blocks and penalties.

            Social Networks

            Decree 147 establishes distinct regimes for offshore and onshore social network services:

            1. Offshore providers meeting the aforementioned threshold must notify the ABEI of their contact information.
            2. Onshore providers reaching 10,000 total visits per month for six consecutive months or 1,000 regular users per month must obtain a Social Network Licence.
            3. Other onshore providers with low traffic must obtain a Notification Certificate from the ABEI.

            The decree also regulates livestream activities by stipulating conditions for social network service providers to offer livestream functions and for social network accounts to conduct livestream activities.

            Online Games

            Foreign organisations and individuals are prohibited from providing online games to service users in Vietnam on a cross-border basis. To offer such services, they must establish a local enterprise in Vietnam.

            This new decree is expected to have a significant impact on both onshore and offshore service providers in the respective fields and may tighten the regulatory landscape for internet services and online information provision in Vietnam.

            “This agreement is not just an economic opportunity. It is a political necessity.” In the current geopolitical context of growing protectionism and significant regional conflicts, Ursula von der Leyen’s statement says a lot.

            Even though there is still a long way to go before the agreement is approved internally in each bloc and comes into force, the milestone is highly significant. It took 25 years from the start of negotiations between Mercosur and the European Union to reach a consensus text. The impacts will be considerable. Together, the blocs represent a GDP of over 22 trillion dollars, and are home to over 700 million people.

            Our aim here is to highlight, in a simplified manner, the most important information about the agreement’s content and its progress, which we will update here at each stage.

            What is it?

            The agreement was signed as a trade treaty, with the main goal of reducing import and export tariffs, eliminating bureaucratic barriers, and facilitating trade between Mercosur countries and European Union members. Additionally, the pact includes commitments in areas such as sustainability, labor rights, technological cooperation, and environmental protection.

            Mercosur (Southern Common Market) is an economic bloc created in 1991 by Brazil, Argentina, Paraguay, and Uruguay. Now, Bolivia and Chile participate as associated members, accessing some trade agreements, but not fully integrated into the common market. On the other hand, the European Union, with its 27 members (20 of which have adopted the common currency), is a broader union with greater economic and social integration compared to Mercosur.

            What does the EU Mercosur agreement include?

            Trade in goods:

            • Reduction or elimination of tariffs on products traded between the blocs, such as meat, grains, fruits, automobiles, wines, and dairy products (the expected reduction will affect over 90% of the traded goods between the blocks).
            • Easier access to European high-tech and industrialized products.

            Trade in services:

            • Expands access to financial services, telecommunications, transportation, and consulting for businesses in both blocs.

            Movement of people:

            • Provides facilities for temporary visas for qualified workers, such as technology professionals and engineers, promoting talent exchange.
            • Encourages educational and cultural cooperation programs.

            Sustainability and environment:

            • Includes commitments to combat deforestation and meet the goals of the Paris Agreement on climate change.
            • Provides penalties for violations of environmental standards.

            Intellectual property and regulations:

            • Protects geographical indications for European cheese, wines, and South American coffee and cachaça.
            • Harmonizes regulatory standards to reduce bureaucracy and avoid technical barriers.

            Labor rights:

            • Commitment to decent working conditions and compliance with International Labor Organization (ILO) standards.

            Which benefits to expect?

            • Access to new markets: Mercosur companies will have easier access to the European market, which has more than 450 million consumers, while European products will become more competitive in South America.
            • Costs reduction: The elimination or reduction of tariffs could lower the prices of products such as wines, cheese, and automobiles and boost South American exports of meat, grains, and fruits.
            • Strengthened diplomatic relations: The agreement symbolizes a bridge of cooperation between two regions historically connected by cultural and economic ties.

            What’s next?

            The signing is only the first step. For the agreement to come into force, it must be ratified by both blocs, and the approval process is quite distinct between them, since Mercosur does not have a common Council or Parliament.

            In the European Union, the ratification process involves multiple institutional steps:

            • Council of the European Union: Ministers from the member states will discuss and approve the text of the agreement. This step is crucial, as each country has representation and may raise specific national concerns.
            • European Parliament: After approval by the Council, the European Parliament, composed of elected deputies, votes to ratify the agreement. The debate at this stage may include environmental, social, and economic impacts.
            • National Parliaments: In cases where the agreement affects shared competencies between the bloc and member states (such as environmental regulations), it must also be approved by the parliaments of each member country. This can be challenging, given that countries like France and Ireland have already expressed specific concerns about agricultural and environmental issues.

            In Mercosur, the approval depends on each member country:

            • National Congresses: The agreement text is submitted to the parliaments of Brazil, Argentina, Paraguay, and Uruguay. Each congress evaluates independently, and approval depends on the political majority in each country.
            • Political Context: Mercosur countries have diverse political realities. In Brazil, for example, environmental issues can spark heated debates, while in Argentina, the impact on agricultural competitiveness may be the focus of discussion.
            • Regional Coordination: Even after national approval, it is necessary to ensure that all Mercosur members ratify the agreement, as the bloc acts as a single negotiating entity.

            Stay tuned: you will find the update here as the processes advance.

            Vietnam has embraced the global minimum tax (GMT) to harmonize its tax policies with global standards. While this new tax regime is anticipated to have certain adverse effects on foreign direct investment (FDI), the Vietnamese government is devising proactive measures to mitigate these repercussions and maintain the country’s appeal as an investment haven.

            Key Ramifications of the GMT for Vietnam

            The GMT mandates multinational corporations (MNCs) with consolidated revenue surpassing €750 million to pay a minimum tax rate of 15%, irrespective of the tax rate in the country where they operate. In Vietnam, this translates to the concept of a qualified domestic minimum top-up tax (QDMTT).

            The QDMTT places an extra tax burden on foreign-invested enterprises (FIEs) that are part of an MNC, potentially deterring them from investing or expanding in Vietnam. This is particularly concerning for industries that heavily rely on tax incentives to attract FDI.

            Vietnam’s Response: Investment Support Fund and Proactive Measures

            In response to the anticipated negative impacts of the GMT, the Vietnamese government has established an investment support fund (Fund) to incentivize investments in targeted sectors. The Fund is primarily funded by proceeds from the State Budget generated by the GMT.

            Eligible enterprises for the Fund are those engaged in high-tech product manufacturing, high-tech enterprises, high-tech application projects, and enterprises with investment projects in research and development centers. Eligibility is based on capital size, annual revenue, industry, or technology utilized.

            Eligible taxpayers can receive cash subsidies for five specific expense categories:

            1. Human resource training and development
            2. Research and development expenses
            3. Fixed asset investments
            4. High-tech manufacturing expenses
            5. Social infrastructure systems

            To qualify for Fund benefits, eligible taxpayers must submit an application dossier to the Fund Office in Hanoi between August 15th and 30th of the year following the incurred Supported Expenses. Each Supported Expense category will have a distinct reimbursement ratio, and support payments will be contingent on the actual expenses incurred by eligible taxpayers.

            In addition to the Fund, the Vietnamese government is also implementing proactive measures to address the concerns of foreign investors. These measures include:

            1. Focusing on targeted industries with high growth potential that align with Vietnam’s strategic development goals
            2. Utilizing the additional revenue collected from top-up tax to enhance infrastructure and labor quality
            3. Considering cash grants for long-term qualified investments in high-tech industries

            Conclusion

            The introduction of the GMT poses challenges for Vietnam in attracting FDI. However, the government’s establishment of the investment support fund and proactive measures demonstrates its commitment to safeguarding the country’s competitiveness as an investment destination. By combining targeted support with infrastructure improvements and incentives for specific industries, Vietnam can mitigate the negative impacts of the GMT and continue to attract foreign investors.

            Summary

            Egypt aims to be Africa’s first green hydrogen producer by incentivizing companies to invest in the sector. Collaborative efforts with Germany and European companies are underway to enhance hydrogen projects and transport. Incentives include financial subsidies, tax exemptions, and administrative advantages, contingent on project conditions like commissioning, foreign funding, local materials use, and community development.

            What is the status of green energy in Egypt and what role does green hydrogen play in this?

            It is currently estimated that Egypt has the potential to generate 350 GW of wind energy and about 650 GW of solar energy per year, as per the Minister of Electricity and Renewable Energy’s (Mohamed Shaker El-Marqabi) declaration. As part of its National Climate Strategy 2050, Egypt has set itself the goal of reducing its carbon emissions, promoting the use of renewable energy sources and using alternative forms of energy, including green hydrogen. The importance the Egyptian government attaches to green hydrogen is evident, not least with the recent cabinet meeting on 17th of May 2023.

            With a view to becoming the first African country to produce green hydrogen, new incentives for green hydrogen and derivatives projects were presented at the cabinet meeting. Based on an investment of 13 billion USD, the legal and financial benefits (new incentive package) that companies in this field can benefit from in the future were presented.

            What agreements exist between Egypt and third countries to promote green hydrogen?

            Agreement between Egypt and Germany on green hydrogen

            The new incentive package was preceded by a meeting between the German-Egyptian Partnership for Green Hydrogen Projects committee and Egyptian officials on the 14th of March 2023. This resulted in a joint roadmap for supporting hydrogen production companies and promoting hydrogen transport and marketing. At this meeting, it was decided that the parties, the Egyptian Minister of International Cooperation (Rania Al-Mashat) and the Egyptian Minister of Public Enterprises (Mahmoud Esmat), will establish a platform to promote the use of green hydrogen.

            At the above-mentioned meeting, Egypt and Germany signed two Memoranda of Understanding (MoU) to enhance cooperation in the field of green hydrogen.

            The Egyptian Government also recently signed other MoUs with seven European leading companies and global alliances to produce new and renewable energy, to establish green hydrogen production complexes in Ain Al-Sokhna and the Red Sea Governorate.

            The German-Egyptian cooperation in the field of green hydrogen follows Egypt’s goal to establish itself as a hub for producing green hydrogen.

            Agreement between Egypt and third countries on green hydrogen

            Egypt has also partnered with the European Union to advance green hydrogen production. Furthermore, in 2022, on the occasion of COP27, Egypt signed a series of MoUs with several international organisations to engage foreign investment in green hydrogen production and make Egypt a transit route for clean energy to Europe.

            MoUs with global companies and alliances have defined the Red Sea Governorate as the location where green hydrogen projects will be carried out in the future.

            Are there investment incentives for the production of green hydrogen in Egypt?

            In the cabinet meeting of 17th of May 2023, the Egyptian Prime Minister Mustafa Madbuli stated that Egypt was offering the “largest” package of investment incentives and facilitations to companies wishing to invest in green hydrogen production projects in Egypt. He further announced the formation of a working group composed of representatives of the authorities involved to elaborate these investment incentives.

            The statement indicated that companies involved in green energy projects in Egypt will benefit from incentives set out in the Law drafted in the cabinet meeting of 17th of May 2023 and Investment Law No. 72 of 2017. This targets companies involved in the “production, storage and export of green hydrogen”.

            What investment incentives for the production of green hydrogen in Egypt are provided for in the draft Law of 17th of May 2023?

            Financial incentives

            Investments in the green hydrogen sector are subsidised in the amount of 33 % to 55 % of the income tax payable. The Ministry of Finance pays the subsidy within 45 days after the deadline for filing the tax return. The subsidy itself is not taxable. The exact conditions for the payment of the subsidy are still to be determined by the Cabinet.

            All machinery, equipment, materials, consumables and vehicles (except private vehicles) used in green hydrogen and derivative projects are exempt from VAT.

            No VAT is levied on exports of green hydrogen and its derivatives.

            The Ministry of Finance pays most of the duties and certification costs associated with setting up the business and all import duties on imported goods used by the establishment. Further, it pays the taxes that would have been levied on the real estate used for the activity, if any.

            Administrative incentives

            Projects in the field of green hydrogen or its derivatives benefit from the so-called golden licence, as it is called in the Investment Law No. 72 of 2017.

            All raw materials, spare parts and vehicles required for operations can be freely imported or exported directly or through distributors without the need for registration in the Importers’ Register.

            The incentives apply to projects and their extensions throughout the contract period if the project agreements are concluded within a maximum of 7 years from the date of commercial commissioning.

            Requirements

            The investment incentives apply when:

            • the project is commissioned within 5 years of the signing of the project agreement
            • at least 70 % of the investment costs come from foreign funds
            • at least 20 % of the locally used materials originate from Egypt
            • training programmes are set up for local workers and know-how is shared
            • the project company draws up a development plan for the communities in which it will operate

            What investment incentives for the production of green hydrogen in Egypt are provided for in the Investment Law No. 72 of 2017?

            The tax incentives granted under the Investment Law No. 72 of 2017 provide for special, general and additional incentives.

            Special incentives

            These are tax reductions limited to 7 years for projects that are started within 3 years (extendable to 6 years) after the provisions of the Law No. 72 of 2017 came into force (i.e. by October 2023). The investment costs consist of equity capital, long-term loans to finance the construction of the project’s movable and immovable assets, and working capital. The tax base is the taxable net profit, which is taxed at the following rates:

            1) Tax exemption on 50 % of the investment costs for the implementation of a project in geographical locations with the greatest development needs (underdeveloped locations) designated by the Central Agency for Public Mobilization and Statistics (CAPMS)

            The law identifies these sites as “Zone A”. According to the implementing regulations, “Zone A” includes:

            • the Suez Canal Economic Zone
            • the Golden Triangle Special Economic Zone
            • the New Administrative Capital Zone
            • the south of Giza province
            • the provinces of Port Said, Ismailia and Suez (east of the canal) connected to the Suez Canal.
            • border provinces, including Red Sea province south of Safaga
            • the provinces in upper Egypt
            • other areas in greatest need of development (to be determined by the Prime Minister)

            2) Tax exemption on 30 % of the investment costs of a project located in the remaining geographical areas outside “Zone A”, referred to as “Zone B”, and operating in certain sectors.

            This includes projects that:

            • are active in the field of renewable energies
            • export their products outside Egypt
            • be carried out by a small or medium-sized (SME)

            General incentives

            Parallel to the special investment incentives, general investment incentives also apply. For example, projects are exempt from certain administrative requirements and fees for a period of 5 years from the date of their registration in the commercial register. Furthermore, temporary duty-free imports and exports are possible.

            Additional incentives

            Additional investment incentives may also be granted by decision of the Council of Ministers:

            • special customs offices for the export or import of the investment project
            • bearing of the value of the utility supply (such as electricity and water supply) of the property intended for the investment project or part thereof by the State
            • partial bearing of the costs of a technical training programme for employees by the State
            • reimbursement of half of the value of the land allocated for industrial projects, provided that the activity was started within two years of the transfer of the land
            • free allocation of land for certain strategic activities
            • under certain conditions, granting of a general permit for the construction, operation and management of the project as well as for the provision of the land required for this purpose. This permit shall also be deemed to be a building permit and shall be effective in its own right without any further action being required. In December 2022, the Egyptian Cabinet granted general approval for several projects.
            • incorporation shares of capital companies subject to the Investment Law No. 72 of 2017 may be traded during the first two fiscal years of the company, subject to the approval of the competent Minister
            • simplified acquisition of real estate, provided it is used for the project

            Takeaways

            • Egypt’s Green Hydrogen Drive: Egypt is strategically embracing green hydrogen production as a pivotal element of its renewable energy vision. The country’s ambitious goals and extensive incentives underscore its commitment to becoming a leading player in the global green energy landscape.
            • International Collaborations: Collaborations with Germany and European partners highlight Egypt’s proactive approach to international cooperation in advancing green hydrogen technologies. Memoranda of Understanding and joint roadmaps are facilitating knowledge exchange and investments for robust hydrogen projects.
            • Comprehensive Incentive Framework: Egypt’s multifaceted incentive framework, including financial subsidies, tax exemptions, and administrative benefits, showcases the government’s determination to attract investments in green hydrogen production. Stringent conditions for benefiting from these incentives emphasize the nation’s dedication to sustainable practices and local community development.

            Geraldo Fonseca

            Practice areas

            • Corporate
            • Credit collection
            • Insolvency
            • International trade
            • Litigation
            Contact Geraldo

            Contact Geraldo





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              Vietnam Tackles Global Minimum Tax Implications

              2 February 2024

              • Vietnam
              • Corporate
              • Foreign investments
              • Tax

              Executive Summary

              The African Continental Free Trade Area (AfCFTA) remains one of the most ambitious integration projects in the world. Yet, several years into its operational phase, it has not (yet) delivered the structural shift many expected. A recent analysis underscores the gap between political momentum and economic reality: implementation remains uneven, the agreement is still used by only a portion of participating states, and non-tariff barriers and infrastructure deficits continue to dominate the cost of doing business across borders.  For Egypt, the opportunity is still real — but it depends less on treaty headlines and more on enabling conditions: trade logistics, customs efficiency, regulatory convergence, and competitive industrial capacity. 

              Looking Back: The Promise of a Single African Market

              When the AfCFTA was launched, expectations were understandably high. A continent-wide trade framework was supposed to reduce tariffs, facilitate trade in goods and services, and strengthen regional value chains — with the broader goal of moving African economies up the value ladder.

              In my 2022 article, I asked whether AfCFTA could become a game changer for Egypt, given Egypt’s industrial base, strategic geography, and the potential to diversify export markets beyond traditional partners. (For background, see the earlier article here”).

              The Reality Check: Intra-African Trade Remains Structurally Weak

              Several years later, the interim assessment is sobering. As the Frankfurter Allgemeine Zeitung (FAZ) recently put it, AfCFTA is not a “game changer” yet, and only about half of member states currently meet the practical prerequisites to trade under the agreement.

              A deeper reason is structural: no other world region trades so little with itself, and while statistics may undercount informal cross-border flows (especially in food), the overall picture remains unchanged.

              Trade integration cannot deliver transformative outcomes if production, logistics, and institutions do not support scale.

              Implementation Has Been Slow — and Often Symbolic

              Operationalisation did not start with full-scale liberalisation. Instead, the AfCFTA began with a pilot approach: the Guided Trade Initiative (GTI) launched in October 2022, initially with eight states, later joined by additional countries, including Nigeria and South Africa by spring 2025.

              The GTI created valuable learning effects, but it also underlined a key point: early progress was often presented through symbolic deals, while product coverage and volumes remained limited. FAZ highlights that only selected goods could be traded duty-free and that key sectors remained constrained for a long time due to missing or unresolved technical rules.

              A pilot, however, cannot substitute for full operational certainty — the kind businesses need to restructure supply chains and invest.

              Tariffs Are Not the Main Barrier — Trade Costs Are

              AfCFTA is frequently discussed in terms of tariff liberalisation. Yet, evidence suggests that the largest gains do not come from tariffs but from reducing non-tariff barriers and improving trade infrastructure.

              FAZ points to a central reality: tariffs tend to add around 20–30% to intra-African trade costs, whereas non-tariff costs can be far higher — driven by bureaucracy, lack of harmonised standards, inefficient border processes, and transport barriers.

              This is the crux: even with reduced tariffs, trade will not expand meaningfully if goods still cannot move cheaply, quickly, and predictably.

              Integration Complexity and Distributional Politics

              Africa’s integration landscape is shaped by multiple overlapping regional economic communities and trade regimes. This creates legal and administrative complexity — often described as an integration “spaghetti bowl.” FAZ notes the challenge of coordination and the continued fragmentation of rules.

              There is also a political economy dimension. Intra-African trade is heavily influenced by a small number of larger economies — and the distribution of benefits matters. FAZ highlights the dominance of major players (notably South Africa) and the concern that tariff liberalisation alone may entrench existing industrial advantages.

              Where governments expect asymmetric outcomes, resistance often takes the form of delay, narrow implementation, or persistent non-tariff barriers.

              What This Means for Egypt: The Opportunity Is Real — But Conditional

              Egypt’s strategic case for AfCFTA participation remains strong: industrial potential, geographic location, and the opportunity to access and shape growing markets. But the experience so far suggests that the treaty text alone does not generate trade flows.

              For Egypt’s private sector, the decisive factors are practical:

              • predictable and efficient customs clearance and border procedures,
              • logistics corridors and port efficiency,
              • regulatory convergence (standards, certification, compliance),
              • stable access to trade finance and payments,
              • competitive energy and production conditions for manufacturing and processing.

              AfCFTA can support these developments — but it cannot replace them.

              The “Game Changer” Pathway: What Must Happen Next

              FAZ concludes that AfCFTA will only become truly impactful if it is paired with the fundamentals: major infrastructure investment, stronger production and processing capacity, and a credible industrial policy.

              At the same time, Africa faces a classic chicken-and-egg problem: without development there is limited investment appeal; without investment there is limited development.

              For Egypt and its partners, a pragmatic strategy would be to:

              1. treat AfCFTA as a platform for real trade-cost reduction, not only tariff debates;
              2. focus on a limited number of scalable corridors and sectors where regional value chains can realistically grow;
              3. strengthen implementation capacity so that preferences become usable for firms — especially SMEs;
              4. enhance legal certainty and dispute resolution reliability for cross-border commerce.

              Conclusion

              AfCFTA remains a landmark achievement in terms of political commitment. But as of today, it has not yet been the “game changer” many hoped for.

              For Egypt, the key question is no longer whether AfCFTA is visionary — it is. The question is whether governments and businesses can translate it into lower real trade costs, higher competitiveness, and bankable cross-border transactions. If those enabling conditions improve, AfCFTA’s promise can still become commercial reality.

              Relocating to Spain for professional reasons is often an exciting step: a new career opportunity, a different lifestyle, and, in many cases, an improved quality of life. However, in practice, the most complex issues rarely arise from employment itself, but from the legal and tax implications surrounding housing.

              Before signing a lease or purchasing a property, it is essential to understand your administrative and tax position in Spain. A proper legal assessment at the outset can prevent costly complications later.

              Immigration Status: The Essential Starting Point

              Not all foreign nationals are in the same legal position.

              Citizens of the European Union may reside and work in Spain, but they must obtain a Foreigner Identification Number (NIE), register with the Central Register of Foreign Nationals, and register their address (empadronamiento) in the municipality where they reside.

              Non-EU nationals, on the other hand, must first secure the appropriate visa or residence and work authorization, and subsequently obtain a Foreigner Identity Card (TIE).

              This is not a mere administrative formality. Without a regularized status, practical issues may arise, including difficulties opening a bank account, setting up utilities, demonstrating financial solvency to landlords, or formalizing deeds before a notary.

              Renting in Spain: What to Review Before Signing

              Residential leases in Spain are governed by the Urban Leases Act (Ley de Arrendamientos Urbanos). Although legal residence is not technically required to sign a lease agreement, landlords often ask for additional guarantees if the tenant has recently arrived in the country.

              It is important to review carefully:

              • The agreed duration of the lease
              • Rent update mechanisms
              • Security deposit and additional guarantees
              • Early termination clauses

              Entering into a lease under time pressure, without fully understanding these terms, can result in financial obligations that may not align with the realities of an international relocation.

              Purchasing Property: Legal Access and Tax Implications

              Foreign nationals may freely acquire real estate in Spain, regardless of residency status. There are no nationality-based restrictions on ownership.

              However, property acquisition has significant tax consequences that should be assessed in advance.

              For resale properties, the Transfer Tax (Impuesto sobre Transmisiones Patrimoniales) applies, with rates varying depending on the Autonomous Community. For newly built properties, VAT (IVA) and Stamp Duty (Actos Jurídicos Documentados) are payable. Notarial and Land Registry fees must also be considered.

              The transaction must be executed through a public deed before a Spanish notary and subsequently registered at the Land Registry to ensure full legal protection against third parties.

              Tax Residency: A Determining Factor

              One of the most critical issues is whether the relocating professional becomes a tax resident in Spain.

              As a general rule, tax residence is acquired by spending more than 183 days in Spain during a calendar year or by having the primary center of economic interests located in Spain. This determination is based on objective criteria and is not dependent solely on municipal registration.

              The distinction is substantial:

              • Spanish tax residents are taxed on their worldwide income.
              • Non-residents are taxed only on income obtained in Spain, under the Non-Resident Income Tax regime.

              Even if a property is not rented, owners may be required to declare imputed income if it does not qualify as their primary residence.

              Coordination with the Country of Origin

              Relocating to Spain does not automatically eliminate tax obligations in the country of origin. Spain has signed numerous double taxation treaties, but their application requires case-by-case analysis.

              Inadequate planning may lead to dual taxation, residency conflicts, or subsequent inquiries from tax authorities in either jurisdiction.

              Plan Before You Commit

              The correct sequence does not begin with signing a lease or reserving a property. It begins with

              • clarifying immigration status
              • defining tax residence, and
              • assessing the legal and financial implications of each decision.

              Housing is not merely a real estate matter. It is a legal and economic commitment with medium- and long-term consequences.

              When a professional move involves crossing borders, careful planning is not optional. It is a fundamental step in protecting both personal stability and the success of the new professional chapter.

              New Regulatory Framework for RHQs: Tax Relief, Substantive Presence, and Streamlined Licensing

              Saudi Arabia has released the long-awaited draft of the “Rules Regulating the Licensing and Supervision of Regional Headquarters of Multinational Companies,” issued pursuant to Cabinet Resolution No. (338) dated 23/4/1445H. This regulatory framework, currently open for public consultation, forms part of the Kingdom’s ambitious Vision 2030 strategy to establish Saudi Arabia as the prime regional base for multinational enterprises (MNEs) operating in the Middle East and North Africa (MENA) region.

              Far beyond mere tax incentives, the draft Rules introduce a binding, structured regime that combines regulatory clarity with strict compliance obligations and long-term benefits. The most salient features include the following.

              30-Year Tax Holiday

              Entities licensed as RHQs will enjoy a 0% income tax rate and a 0% withholding tax rate on dividends, related-party payments, and payments for services essential to RHQ activity. These tax incentives are granted for a period of 30 years, renewable under conditions set by the Ministry of Investment.

              Operational Substance Requirements: RHQ Functions and Compliance

              At the core of the RHQ regime lies the requirement for substantial and sustained business presence in the Kingdom. Licensed RHQs must activate both mandatory and optional activities as defined in Article 7 of the Rules:

              Mandatory Activities (to be activated within the first year):

              • Preparation and implementation of the regional strategy;
              • Strategic coordination of the MNE’s operations in the region;
              • Selection of products and services offered in the region;
              • M&A support;
              • Financial performance review;
              • Budget planning for regional operations;
              • Coordination of business units across MENA;
              • Market research and competitor analysis;
              • Identification of new market opportunities;
              • Marketing strategy development;
              • Preparation of operational and financial reports.

              Optional Activities (minimum of three to be activated): These include, among others:

              • Research, development and innovation;
              • Sales and marketing;
              • Human resources and training;
              • Financial management, foreign exchange and treasury services;
              • Legal consultancy, compliance, internal audit;
              • Logistics, IP management, production, and technical support.

              The selected optional activities must be aligned with the MNE’s global business strategy and must be regionally anchored.

              Additional Substantive Requirements

              • Minimum of 15 employees in the first year;
              • At least 3 senior executives must be based in the Kingdom and must represent the top decision-making authority for the region;
              • RHQ staff must reside in Saudi Arabia, be dedicated full-time, be licensed locally, and receive remuneration through Saudi bank accounts;
              • RHQ operations must be exclusively performed within the Kingdom.

              Licensing Process and Timing

              The licensing process is clearly defined. Upon submission of the required documentation (commercial records, financials, activity plans), the Ministry of Investment will process the application within 30 working days.

              True Regional Authority and Kingdom-Centric Operations

              Licensed RHQs must hold administrative authority over all regional branches and subsidiaries. The RHQ must operate as the highest strategic, executive, and administrative authority in the MENA region. Furthermore, all RHQ-related activities must be carried out exclusively from within the Kingdom.

              Localization Requirements

              To ensure genuine local presence, the RHQ regime mandates:

              • Saudi residency and work permits for all RHQ personnel;
              • No hybrid or remote models from abroad;
              • Local registration of intellectual property and commercial identifiers;
              • Internal reporting and supervision obligations anchored in Saudi Arabia.

              Is RHQ Establishment Mandatory or Optional?

              While the RHQ license remains optional in principle, it is effectively mandatory for all multinational companies intending to contract with Saudi public sector entities.

              As of 1 January 2024, the Saudi government will only consider public procurement contracts from companies that have an RHQ presence in the Kingdom, unless an express exemption is granted. Companies operating purely in the private sector without government contracts remain unaffected, but will nonetheless benefit from the RHQ regime if they choose to participate.

              This regulatory shift creates a strategic filter: those seeking to participate in Saudi Arabia’s transformation across infrastructure, health, energy, and education must establish a fully embedded regional presence in the Kingdom.

              Conclusion: High-Reward, High-Compliance Environment

              The draft Rules represent a bold step in reshaping the MENA business landscape. Saudi Arabia is setting the bar high: generous tax relief and fast-track licensing are tied to substantive commitments in structure, personnel, and governance. For MNEs willing to assume regional leadership from within Saudi borders, the opportunity is as attractive as it is demanding.

              A dedicated notary account in Brazil is a legal mechanism that brings greater security, transparency, and reliability to financial transactions. Regulated under Law 8.935/1994 and Provision No. 197/2025, this service allows notaries to receive, manage, and release funds only after contractual conditions have been fulfilled. By ensuring segregation of assets, traceability, and impartial oversight, dedicated notary accounts provide an effective escrow-like solution for real estate deals, mergers and acquisitions, import/export operations, high-value asset purchases, and complex commercial contracts. This tool not only reduces legal risks and potential disputes but also strengthens trust between parties by guaranteeing that payments are safeguarded until obligations are met.

              The legal basis can be found in Law 8.935/1994, § 1 of art. 7-A, which allows notaries to receive, deposit, and manage amounts related to legal transactions, with transactions subject to objectively verifiable facts/conditions. Provision No. 197, dated June 13, 2025, regulates, at the national level, the service of notarial accounts linked to Notary Public Offices.

              Practical applications: among others, in the following transactions:

              • Real estate: guarantee that the down payment and settlement amounts will be secured in a specific account. This mitigates the risk of misappropriation of funds and ensures that the money will be released only after all contractual conditions have been met.
              • M&A: the linked notarial account creates a standardized escrow mechanism for the payment of price/holdbacks/earn-outs and conditional obligations.
              • Purchase and Sale of High-Value Movable Property: the linked account can be used to guarantee payment. The buyer deposits the amount and the seller knows that the money is safe, being released only after the transfer of ownership and delivery of the goods.
              • Import and Export: the transaction amount can be deposited with the notary and released to the exporter only after confirmation of delivery of the goods in the destination country, for example.
              • Guarantee of Obligations: In any contract that provides for the payment of a sum of money as a guarantee, the notary account can be used to provide greater security to the parties.
              • Supply, EPC/turnkey, and construction contracts: performance retentions, milestone acceptance (commissioning, as-built, issuance of ART/CREA), and payment against formal acceptance.
              • Contractual joint ventures and commercial partnerships: advances conditional on licenses, authorizations, or competitive approval, where applicable.

              Reduction of Legal Risks: The use of linked accounts reduces the chances of litigation related to lack of clarity about the origin and destination of funds. Companies can clearly demonstrate that payments were made and held by an impartial and secure institution.

              Operational structure: limited to banking entities affiliated with the CNB, which must ensure the segregation of assets, traceability through audit trails, and proof of all transactions. The authorization of the delegate requires prior accreditation and electronic registration of the essential details of the transaction and its conditions in the CNB system, with access restricted to the parties and the notary.

              Specific Purpose: amounts received as payment, guarantee, or advance payment as a result of notarial acts must be deposited in a bank account linked to the specific act and may only be moved for the purpose for which they are intended.

              Transparency and Traceability: With the linked notarial account, it is possible to clearly track the financial flow of each transaction, which increases transparency for all parties and for supervisory bodies.

              Verification of conditions and release. Once the objective conditions have been met, the notary authorizes the transfer to the recipients and files the proof of verification. In the event of a dispute between the parties, the notary suspends any movement, draws up a notarial deed, and advises on a consensual or judicial solution, without deciding on the effectiveness/termination of the transaction; if the transaction is frustrated and no solution is found, the procedure is terminated and the amounts are returned to the depositor, in accordance with the agreed clauses.

              Confidentiality and access. In transactions with a confidentiality clause, the notary public maintains confidentiality and does not issue certificates regarding the content of the transaction; documents are accessible only for correctional purposes or by court order.

              Remuneration and costs. The notary’s remuneration for the notarial account service is paid by the financial institution under the terms of the agreement, and the transfer of additional costs to the user is prohibited, without prejudice to fees for any related notarial acts.

              The Government of Vietnam has issued a new decree governing internet services and online information, which shall come into force on 25 December 2024. Decree No. 147/2024/ND-CP, promulgated on 9 November 2024, supersedes the previous Decree No. 72/2013/ND-CP and its amendments.

              This comprehensive legislation, comprising over 200 pages and 62 appended forms, addresses a wide array of internet and online topics. These include inter alia, internet services, domain names, cross-border information provision, social network services, aggregated information websites, online game services, and app store services.

              Key Provisions

              Cross-Border Information Provision

              Offshore service providers, including those offering social network and app store services on a cross-border basis, are subject to stricter requirements if they either lease data storage in Vietnam or meet a threshold of 100,000 or more total visits per month from Vietnam for six consecutive months. These providers must:

              1. Notify the Authority of Broadcasting and Electronic Information (ABEI) of their contact information
              2. Monitor and remove illegal content
              3. Store and manage user data as required
              4. Authenticate social network user accounts using Vietnamese mobile numbers or identification numbers
              5. Submit annual and ad hoc reports to the ABEI
              6. Handle user complaints

              Only cross-border providers who have notified the ABEI of their contact details may offer live stream and revenue-generating services. Non-compliance may result in blocks and penalties.

              Social Networks

              Decree 147 establishes distinct regimes for offshore and onshore social network services:

              1. Offshore providers meeting the aforementioned threshold must notify the ABEI of their contact information.
              2. Onshore providers reaching 10,000 total visits per month for six consecutive months or 1,000 regular users per month must obtain a Social Network Licence.
              3. Other onshore providers with low traffic must obtain a Notification Certificate from the ABEI.

              The decree also regulates livestream activities by stipulating conditions for social network service providers to offer livestream functions and for social network accounts to conduct livestream activities.

              Online Games

              Foreign organisations and individuals are prohibited from providing online games to service users in Vietnam on a cross-border basis. To offer such services, they must establish a local enterprise in Vietnam.

              This new decree is expected to have a significant impact on both onshore and offshore service providers in the respective fields and may tighten the regulatory landscape for internet services and online information provision in Vietnam.

              “This agreement is not just an economic opportunity. It is a political necessity.” In the current geopolitical context of growing protectionism and significant regional conflicts, Ursula von der Leyen’s statement says a lot.

              Even though there is still a long way to go before the agreement is approved internally in each bloc and comes into force, the milestone is highly significant. It took 25 years from the start of negotiations between Mercosur and the European Union to reach a consensus text. The impacts will be considerable. Together, the blocs represent a GDP of over 22 trillion dollars, and are home to over 700 million people.

              Our aim here is to highlight, in a simplified manner, the most important information about the agreement’s content and its progress, which we will update here at each stage.

              What is it?

              The agreement was signed as a trade treaty, with the main goal of reducing import and export tariffs, eliminating bureaucratic barriers, and facilitating trade between Mercosur countries and European Union members. Additionally, the pact includes commitments in areas such as sustainability, labor rights, technological cooperation, and environmental protection.

              Mercosur (Southern Common Market) is an economic bloc created in 1991 by Brazil, Argentina, Paraguay, and Uruguay. Now, Bolivia and Chile participate as associated members, accessing some trade agreements, but not fully integrated into the common market. On the other hand, the European Union, with its 27 members (20 of which have adopted the common currency), is a broader union with greater economic and social integration compared to Mercosur.

              What does the EU Mercosur agreement include?

              Trade in goods:

              • Reduction or elimination of tariffs on products traded between the blocs, such as meat, grains, fruits, automobiles, wines, and dairy products (the expected reduction will affect over 90% of the traded goods between the blocks).
              • Easier access to European high-tech and industrialized products.

              Trade in services:

              • Expands access to financial services, telecommunications, transportation, and consulting for businesses in both blocs.

              Movement of people:

              • Provides facilities for temporary visas for qualified workers, such as technology professionals and engineers, promoting talent exchange.
              • Encourages educational and cultural cooperation programs.

              Sustainability and environment:

              • Includes commitments to combat deforestation and meet the goals of the Paris Agreement on climate change.
              • Provides penalties for violations of environmental standards.

              Intellectual property and regulations:

              • Protects geographical indications for European cheese, wines, and South American coffee and cachaça.
              • Harmonizes regulatory standards to reduce bureaucracy and avoid technical barriers.

              Labor rights:

              • Commitment to decent working conditions and compliance with International Labor Organization (ILO) standards.

              Which benefits to expect?

              • Access to new markets: Mercosur companies will have easier access to the European market, which has more than 450 million consumers, while European products will become more competitive in South America.
              • Costs reduction: The elimination or reduction of tariffs could lower the prices of products such as wines, cheese, and automobiles and boost South American exports of meat, grains, and fruits.
              • Strengthened diplomatic relations: The agreement symbolizes a bridge of cooperation between two regions historically connected by cultural and economic ties.

              What’s next?

              The signing is only the first step. For the agreement to come into force, it must be ratified by both blocs, and the approval process is quite distinct between them, since Mercosur does not have a common Council or Parliament.

              In the European Union, the ratification process involves multiple institutional steps:

              • Council of the European Union: Ministers from the member states will discuss and approve the text of the agreement. This step is crucial, as each country has representation and may raise specific national concerns.
              • European Parliament: After approval by the Council, the European Parliament, composed of elected deputies, votes to ratify the agreement. The debate at this stage may include environmental, social, and economic impacts.
              • National Parliaments: In cases where the agreement affects shared competencies between the bloc and member states (such as environmental regulations), it must also be approved by the parliaments of each member country. This can be challenging, given that countries like France and Ireland have already expressed specific concerns about agricultural and environmental issues.

              In Mercosur, the approval depends on each member country:

              • National Congresses: The agreement text is submitted to the parliaments of Brazil, Argentina, Paraguay, and Uruguay. Each congress evaluates independently, and approval depends on the political majority in each country.
              • Political Context: Mercosur countries have diverse political realities. In Brazil, for example, environmental issues can spark heated debates, while in Argentina, the impact on agricultural competitiveness may be the focus of discussion.
              • Regional Coordination: Even after national approval, it is necessary to ensure that all Mercosur members ratify the agreement, as the bloc acts as a single negotiating entity.

              Stay tuned: you will find the update here as the processes advance.

              Vietnam has embraced the global minimum tax (GMT) to harmonize its tax policies with global standards. While this new tax regime is anticipated to have certain adverse effects on foreign direct investment (FDI), the Vietnamese government is devising proactive measures to mitigate these repercussions and maintain the country’s appeal as an investment haven.

              Key Ramifications of the GMT for Vietnam

              The GMT mandates multinational corporations (MNCs) with consolidated revenue surpassing €750 million to pay a minimum tax rate of 15%, irrespective of the tax rate in the country where they operate. In Vietnam, this translates to the concept of a qualified domestic minimum top-up tax (QDMTT).

              The QDMTT places an extra tax burden on foreign-invested enterprises (FIEs) that are part of an MNC, potentially deterring them from investing or expanding in Vietnam. This is particularly concerning for industries that heavily rely on tax incentives to attract FDI.

              Vietnam’s Response: Investment Support Fund and Proactive Measures

              In response to the anticipated negative impacts of the GMT, the Vietnamese government has established an investment support fund (Fund) to incentivize investments in targeted sectors. The Fund is primarily funded by proceeds from the State Budget generated by the GMT.

              Eligible enterprises for the Fund are those engaged in high-tech product manufacturing, high-tech enterprises, high-tech application projects, and enterprises with investment projects in research and development centers. Eligibility is based on capital size, annual revenue, industry, or technology utilized.

              Eligible taxpayers can receive cash subsidies for five specific expense categories:

              1. Human resource training and development
              2. Research and development expenses
              3. Fixed asset investments
              4. High-tech manufacturing expenses
              5. Social infrastructure systems

              To qualify for Fund benefits, eligible taxpayers must submit an application dossier to the Fund Office in Hanoi between August 15th and 30th of the year following the incurred Supported Expenses. Each Supported Expense category will have a distinct reimbursement ratio, and support payments will be contingent on the actual expenses incurred by eligible taxpayers.

              In addition to the Fund, the Vietnamese government is also implementing proactive measures to address the concerns of foreign investors. These measures include:

              1. Focusing on targeted industries with high growth potential that align with Vietnam’s strategic development goals
              2. Utilizing the additional revenue collected from top-up tax to enhance infrastructure and labor quality
              3. Considering cash grants for long-term qualified investments in high-tech industries

              Conclusion

              The introduction of the GMT poses challenges for Vietnam in attracting FDI. However, the government’s establishment of the investment support fund and proactive measures demonstrates its commitment to safeguarding the country’s competitiveness as an investment destination. By combining targeted support with infrastructure improvements and incentives for specific industries, Vietnam can mitigate the negative impacts of the GMT and continue to attract foreign investors.

              Summary

              Egypt aims to be Africa’s first green hydrogen producer by incentivizing companies to invest in the sector. Collaborative efforts with Germany and European companies are underway to enhance hydrogen projects and transport. Incentives include financial subsidies, tax exemptions, and administrative advantages, contingent on project conditions like commissioning, foreign funding, local materials use, and community development.

              What is the status of green energy in Egypt and what role does green hydrogen play in this?

              It is currently estimated that Egypt has the potential to generate 350 GW of wind energy and about 650 GW of solar energy per year, as per the Minister of Electricity and Renewable Energy’s (Mohamed Shaker El-Marqabi) declaration. As part of its National Climate Strategy 2050, Egypt has set itself the goal of reducing its carbon emissions, promoting the use of renewable energy sources and using alternative forms of energy, including green hydrogen. The importance the Egyptian government attaches to green hydrogen is evident, not least with the recent cabinet meeting on 17th of May 2023.

              With a view to becoming the first African country to produce green hydrogen, new incentives for green hydrogen and derivatives projects were presented at the cabinet meeting. Based on an investment of 13 billion USD, the legal and financial benefits (new incentive package) that companies in this field can benefit from in the future were presented.

              What agreements exist between Egypt and third countries to promote green hydrogen?

              Agreement between Egypt and Germany on green hydrogen

              The new incentive package was preceded by a meeting between the German-Egyptian Partnership for Green Hydrogen Projects committee and Egyptian officials on the 14th of March 2023. This resulted in a joint roadmap for supporting hydrogen production companies and promoting hydrogen transport and marketing. At this meeting, it was decided that the parties, the Egyptian Minister of International Cooperation (Rania Al-Mashat) and the Egyptian Minister of Public Enterprises (Mahmoud Esmat), will establish a platform to promote the use of green hydrogen.

              At the above-mentioned meeting, Egypt and Germany signed two Memoranda of Understanding (MoU) to enhance cooperation in the field of green hydrogen.

              The Egyptian Government also recently signed other MoUs with seven European leading companies and global alliances to produce new and renewable energy, to establish green hydrogen production complexes in Ain Al-Sokhna and the Red Sea Governorate.

              The German-Egyptian cooperation in the field of green hydrogen follows Egypt’s goal to establish itself as a hub for producing green hydrogen.

              Agreement between Egypt and third countries on green hydrogen

              Egypt has also partnered with the European Union to advance green hydrogen production. Furthermore, in 2022, on the occasion of COP27, Egypt signed a series of MoUs with several international organisations to engage foreign investment in green hydrogen production and make Egypt a transit route for clean energy to Europe.

              MoUs with global companies and alliances have defined the Red Sea Governorate as the location where green hydrogen projects will be carried out in the future.

              Are there investment incentives for the production of green hydrogen in Egypt?

              In the cabinet meeting of 17th of May 2023, the Egyptian Prime Minister Mustafa Madbuli stated that Egypt was offering the “largest” package of investment incentives and facilitations to companies wishing to invest in green hydrogen production projects in Egypt. He further announced the formation of a working group composed of representatives of the authorities involved to elaborate these investment incentives.

              The statement indicated that companies involved in green energy projects in Egypt will benefit from incentives set out in the Law drafted in the cabinet meeting of 17th of May 2023 and Investment Law No. 72 of 2017. This targets companies involved in the “production, storage and export of green hydrogen”.

              What investment incentives for the production of green hydrogen in Egypt are provided for in the draft Law of 17th of May 2023?

              Financial incentives

              Investments in the green hydrogen sector are subsidised in the amount of 33 % to 55 % of the income tax payable. The Ministry of Finance pays the subsidy within 45 days after the deadline for filing the tax return. The subsidy itself is not taxable. The exact conditions for the payment of the subsidy are still to be determined by the Cabinet.

              All machinery, equipment, materials, consumables and vehicles (except private vehicles) used in green hydrogen and derivative projects are exempt from VAT.

              No VAT is levied on exports of green hydrogen and its derivatives.

              The Ministry of Finance pays most of the duties and certification costs associated with setting up the business and all import duties on imported goods used by the establishment. Further, it pays the taxes that would have been levied on the real estate used for the activity, if any.

              Administrative incentives

              Projects in the field of green hydrogen or its derivatives benefit from the so-called golden licence, as it is called in the Investment Law No. 72 of 2017.

              All raw materials, spare parts and vehicles required for operations can be freely imported or exported directly or through distributors without the need for registration in the Importers’ Register.

              The incentives apply to projects and their extensions throughout the contract period if the project agreements are concluded within a maximum of 7 years from the date of commercial commissioning.

              Requirements

              The investment incentives apply when:

              • the project is commissioned within 5 years of the signing of the project agreement
              • at least 70 % of the investment costs come from foreign funds
              • at least 20 % of the locally used materials originate from Egypt
              • training programmes are set up for local workers and know-how is shared
              • the project company draws up a development plan for the communities in which it will operate

              What investment incentives for the production of green hydrogen in Egypt are provided for in the Investment Law No. 72 of 2017?

              The tax incentives granted under the Investment Law No. 72 of 2017 provide for special, general and additional incentives.

              Special incentives

              These are tax reductions limited to 7 years for projects that are started within 3 years (extendable to 6 years) after the provisions of the Law No. 72 of 2017 came into force (i.e. by October 2023). The investment costs consist of equity capital, long-term loans to finance the construction of the project’s movable and immovable assets, and working capital. The tax base is the taxable net profit, which is taxed at the following rates:

              1) Tax exemption on 50 % of the investment costs for the implementation of a project in geographical locations with the greatest development needs (underdeveloped locations) designated by the Central Agency for Public Mobilization and Statistics (CAPMS)

              The law identifies these sites as “Zone A”. According to the implementing regulations, “Zone A” includes:

              • the Suez Canal Economic Zone
              • the Golden Triangle Special Economic Zone
              • the New Administrative Capital Zone
              • the south of Giza province
              • the provinces of Port Said, Ismailia and Suez (east of the canal) connected to the Suez Canal.
              • border provinces, including Red Sea province south of Safaga
              • the provinces in upper Egypt
              • other areas in greatest need of development (to be determined by the Prime Minister)

              2) Tax exemption on 30 % of the investment costs of a project located in the remaining geographical areas outside “Zone A”, referred to as “Zone B”, and operating in certain sectors.

              This includes projects that:

              • are active in the field of renewable energies
              • export their products outside Egypt
              • be carried out by a small or medium-sized (SME)

              General incentives

              Parallel to the special investment incentives, general investment incentives also apply. For example, projects are exempt from certain administrative requirements and fees for a period of 5 years from the date of their registration in the commercial register. Furthermore, temporary duty-free imports and exports are possible.

              Additional incentives

              Additional investment incentives may also be granted by decision of the Council of Ministers:

              • special customs offices for the export or import of the investment project
              • bearing of the value of the utility supply (such as electricity and water supply) of the property intended for the investment project or part thereof by the State
              • partial bearing of the costs of a technical training programme for employees by the State
              • reimbursement of half of the value of the land allocated for industrial projects, provided that the activity was started within two years of the transfer of the land
              • free allocation of land for certain strategic activities
              • under certain conditions, granting of a general permit for the construction, operation and management of the project as well as for the provision of the land required for this purpose. This permit shall also be deemed to be a building permit and shall be effective in its own right without any further action being required. In December 2022, the Egyptian Cabinet granted general approval for several projects.
              • incorporation shares of capital companies subject to the Investment Law No. 72 of 2017 may be traded during the first two fiscal years of the company, subject to the approval of the competent Minister
              • simplified acquisition of real estate, provided it is used for the project

              Takeaways

              • Egypt’s Green Hydrogen Drive: Egypt is strategically embracing green hydrogen production as a pivotal element of its renewable energy vision. The country’s ambitious goals and extensive incentives underscore its commitment to becoming a leading player in the global green energy landscape.
              • International Collaborations: Collaborations with Germany and European partners highlight Egypt’s proactive approach to international cooperation in advancing green hydrogen technologies. Memoranda of Understanding and joint roadmaps are facilitating knowledge exchange and investments for robust hydrogen projects.
              • Comprehensive Incentive Framework: Egypt’s multifaceted incentive framework, including financial subsidies, tax exemptions, and administrative benefits, showcases the government’s determination to attract investments in green hydrogen production. Stringent conditions for benefiting from these incentives emphasize the nation’s dedication to sustainable practices and local community development.

              Federico Vasoli

              Practice areas

              • Corporate
              • Foreign investments
              • M&A
              Contact Federico

              Contact Federico





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                Incentives for green hydrogen production in Egypt

                25 August 2023

                • Egypt
                • Foreign investments
                • Agency
                • Renewable Energy

                Executive Summary

                The African Continental Free Trade Area (AfCFTA) remains one of the most ambitious integration projects in the world. Yet, several years into its operational phase, it has not (yet) delivered the structural shift many expected. A recent analysis underscores the gap between political momentum and economic reality: implementation remains uneven, the agreement is still used by only a portion of participating states, and non-tariff barriers and infrastructure deficits continue to dominate the cost of doing business across borders.  For Egypt, the opportunity is still real — but it depends less on treaty headlines and more on enabling conditions: trade logistics, customs efficiency, regulatory convergence, and competitive industrial capacity. 

                Looking Back: The Promise of a Single African Market

                When the AfCFTA was launched, expectations were understandably high. A continent-wide trade framework was supposed to reduce tariffs, facilitate trade in goods and services, and strengthen regional value chains — with the broader goal of moving African economies up the value ladder.

                In my 2022 article, I asked whether AfCFTA could become a game changer for Egypt, given Egypt’s industrial base, strategic geography, and the potential to diversify export markets beyond traditional partners. (For background, see the earlier article here”).

                The Reality Check: Intra-African Trade Remains Structurally Weak

                Several years later, the interim assessment is sobering. As the Frankfurter Allgemeine Zeitung (FAZ) recently put it, AfCFTA is not a “game changer” yet, and only about half of member states currently meet the practical prerequisites to trade under the agreement.

                A deeper reason is structural: no other world region trades so little with itself, and while statistics may undercount informal cross-border flows (especially in food), the overall picture remains unchanged.

                Trade integration cannot deliver transformative outcomes if production, logistics, and institutions do not support scale.

                Implementation Has Been Slow — and Often Symbolic

                Operationalisation did not start with full-scale liberalisation. Instead, the AfCFTA began with a pilot approach: the Guided Trade Initiative (GTI) launched in October 2022, initially with eight states, later joined by additional countries, including Nigeria and South Africa by spring 2025.

                The GTI created valuable learning effects, but it also underlined a key point: early progress was often presented through symbolic deals, while product coverage and volumes remained limited. FAZ highlights that only selected goods could be traded duty-free and that key sectors remained constrained for a long time due to missing or unresolved technical rules.

                A pilot, however, cannot substitute for full operational certainty — the kind businesses need to restructure supply chains and invest.

                Tariffs Are Not the Main Barrier — Trade Costs Are

                AfCFTA is frequently discussed in terms of tariff liberalisation. Yet, evidence suggests that the largest gains do not come from tariffs but from reducing non-tariff barriers and improving trade infrastructure.

                FAZ points to a central reality: tariffs tend to add around 20–30% to intra-African trade costs, whereas non-tariff costs can be far higher — driven by bureaucracy, lack of harmonised standards, inefficient border processes, and transport barriers.

                This is the crux: even with reduced tariffs, trade will not expand meaningfully if goods still cannot move cheaply, quickly, and predictably.

                Integration Complexity and Distributional Politics

                Africa’s integration landscape is shaped by multiple overlapping regional economic communities and trade regimes. This creates legal and administrative complexity — often described as an integration “spaghetti bowl.” FAZ notes the challenge of coordination and the continued fragmentation of rules.

                There is also a political economy dimension. Intra-African trade is heavily influenced by a small number of larger economies — and the distribution of benefits matters. FAZ highlights the dominance of major players (notably South Africa) and the concern that tariff liberalisation alone may entrench existing industrial advantages.

                Where governments expect asymmetric outcomes, resistance often takes the form of delay, narrow implementation, or persistent non-tariff barriers.

                What This Means for Egypt: The Opportunity Is Real — But Conditional

                Egypt’s strategic case for AfCFTA participation remains strong: industrial potential, geographic location, and the opportunity to access and shape growing markets. But the experience so far suggests that the treaty text alone does not generate trade flows.

                For Egypt’s private sector, the decisive factors are practical:

                • predictable and efficient customs clearance and border procedures,
                • logistics corridors and port efficiency,
                • regulatory convergence (standards, certification, compliance),
                • stable access to trade finance and payments,
                • competitive energy and production conditions for manufacturing and processing.

                AfCFTA can support these developments — but it cannot replace them.

                The “Game Changer” Pathway: What Must Happen Next

                FAZ concludes that AfCFTA will only become truly impactful if it is paired with the fundamentals: major infrastructure investment, stronger production and processing capacity, and a credible industrial policy.

                At the same time, Africa faces a classic chicken-and-egg problem: without development there is limited investment appeal; without investment there is limited development.

                For Egypt and its partners, a pragmatic strategy would be to:

                1. treat AfCFTA as a platform for real trade-cost reduction, not only tariff debates;
                2. focus on a limited number of scalable corridors and sectors where regional value chains can realistically grow;
                3. strengthen implementation capacity so that preferences become usable for firms — especially SMEs;
                4. enhance legal certainty and dispute resolution reliability for cross-border commerce.

                Conclusion

                AfCFTA remains a landmark achievement in terms of political commitment. But as of today, it has not yet been the “game changer” many hoped for.

                For Egypt, the key question is no longer whether AfCFTA is visionary — it is. The question is whether governments and businesses can translate it into lower real trade costs, higher competitiveness, and bankable cross-border transactions. If those enabling conditions improve, AfCFTA’s promise can still become commercial reality.

                Relocating to Spain for professional reasons is often an exciting step: a new career opportunity, a different lifestyle, and, in many cases, an improved quality of life. However, in practice, the most complex issues rarely arise from employment itself, but from the legal and tax implications surrounding housing.

                Before signing a lease or purchasing a property, it is essential to understand your administrative and tax position in Spain. A proper legal assessment at the outset can prevent costly complications later.

                Immigration Status: The Essential Starting Point

                Not all foreign nationals are in the same legal position.

                Citizens of the European Union may reside and work in Spain, but they must obtain a Foreigner Identification Number (NIE), register with the Central Register of Foreign Nationals, and register their address (empadronamiento) in the municipality where they reside.

                Non-EU nationals, on the other hand, must first secure the appropriate visa or residence and work authorization, and subsequently obtain a Foreigner Identity Card (TIE).

                This is not a mere administrative formality. Without a regularized status, practical issues may arise, including difficulties opening a bank account, setting up utilities, demonstrating financial solvency to landlords, or formalizing deeds before a notary.

                Renting in Spain: What to Review Before Signing

                Residential leases in Spain are governed by the Urban Leases Act (Ley de Arrendamientos Urbanos). Although legal residence is not technically required to sign a lease agreement, landlords often ask for additional guarantees if the tenant has recently arrived in the country.

                It is important to review carefully:

                • The agreed duration of the lease
                • Rent update mechanisms
                • Security deposit and additional guarantees
                • Early termination clauses

                Entering into a lease under time pressure, without fully understanding these terms, can result in financial obligations that may not align with the realities of an international relocation.

                Purchasing Property: Legal Access and Tax Implications

                Foreign nationals may freely acquire real estate in Spain, regardless of residency status. There are no nationality-based restrictions on ownership.

                However, property acquisition has significant tax consequences that should be assessed in advance.

                For resale properties, the Transfer Tax (Impuesto sobre Transmisiones Patrimoniales) applies, with rates varying depending on the Autonomous Community. For newly built properties, VAT (IVA) and Stamp Duty (Actos Jurídicos Documentados) are payable. Notarial and Land Registry fees must also be considered.

                The transaction must be executed through a public deed before a Spanish notary and subsequently registered at the Land Registry to ensure full legal protection against third parties.

                Tax Residency: A Determining Factor

                One of the most critical issues is whether the relocating professional becomes a tax resident in Spain.

                As a general rule, tax residence is acquired by spending more than 183 days in Spain during a calendar year or by having the primary center of economic interests located in Spain. This determination is based on objective criteria and is not dependent solely on municipal registration.

                The distinction is substantial:

                • Spanish tax residents are taxed on their worldwide income.
                • Non-residents are taxed only on income obtained in Spain, under the Non-Resident Income Tax regime.

                Even if a property is not rented, owners may be required to declare imputed income if it does not qualify as their primary residence.

                Coordination with the Country of Origin

                Relocating to Spain does not automatically eliminate tax obligations in the country of origin. Spain has signed numerous double taxation treaties, but their application requires case-by-case analysis.

                Inadequate planning may lead to dual taxation, residency conflicts, or subsequent inquiries from tax authorities in either jurisdiction.

                Plan Before You Commit

                The correct sequence does not begin with signing a lease or reserving a property. It begins with

                • clarifying immigration status
                • defining tax residence, and
                • assessing the legal and financial implications of each decision.

                Housing is not merely a real estate matter. It is a legal and economic commitment with medium- and long-term consequences.

                When a professional move involves crossing borders, careful planning is not optional. It is a fundamental step in protecting both personal stability and the success of the new professional chapter.

                New Regulatory Framework for RHQs: Tax Relief, Substantive Presence, and Streamlined Licensing

                Saudi Arabia has released the long-awaited draft of the “Rules Regulating the Licensing and Supervision of Regional Headquarters of Multinational Companies,” issued pursuant to Cabinet Resolution No. (338) dated 23/4/1445H. This regulatory framework, currently open for public consultation, forms part of the Kingdom’s ambitious Vision 2030 strategy to establish Saudi Arabia as the prime regional base for multinational enterprises (MNEs) operating in the Middle East and North Africa (MENA) region.

                Far beyond mere tax incentives, the draft Rules introduce a binding, structured regime that combines regulatory clarity with strict compliance obligations and long-term benefits. The most salient features include the following.

                30-Year Tax Holiday

                Entities licensed as RHQs will enjoy a 0% income tax rate and a 0% withholding tax rate on dividends, related-party payments, and payments for services essential to RHQ activity. These tax incentives are granted for a period of 30 years, renewable under conditions set by the Ministry of Investment.

                Operational Substance Requirements: RHQ Functions and Compliance

                At the core of the RHQ regime lies the requirement for substantial and sustained business presence in the Kingdom. Licensed RHQs must activate both mandatory and optional activities as defined in Article 7 of the Rules:

                Mandatory Activities (to be activated within the first year):

                • Preparation and implementation of the regional strategy;
                • Strategic coordination of the MNE’s operations in the region;
                • Selection of products and services offered in the region;
                • M&A support;
                • Financial performance review;
                • Budget planning for regional operations;
                • Coordination of business units across MENA;
                • Market research and competitor analysis;
                • Identification of new market opportunities;
                • Marketing strategy development;
                • Preparation of operational and financial reports.

                Optional Activities (minimum of three to be activated): These include, among others:

                • Research, development and innovation;
                • Sales and marketing;
                • Human resources and training;
                • Financial management, foreign exchange and treasury services;
                • Legal consultancy, compliance, internal audit;
                • Logistics, IP management, production, and technical support.

                The selected optional activities must be aligned with the MNE’s global business strategy and must be regionally anchored.

                Additional Substantive Requirements

                • Minimum of 15 employees in the first year;
                • At least 3 senior executives must be based in the Kingdom and must represent the top decision-making authority for the region;
                • RHQ staff must reside in Saudi Arabia, be dedicated full-time, be licensed locally, and receive remuneration through Saudi bank accounts;
                • RHQ operations must be exclusively performed within the Kingdom.

                Licensing Process and Timing

                The licensing process is clearly defined. Upon submission of the required documentation (commercial records, financials, activity plans), the Ministry of Investment will process the application within 30 working days.

                True Regional Authority and Kingdom-Centric Operations

                Licensed RHQs must hold administrative authority over all regional branches and subsidiaries. The RHQ must operate as the highest strategic, executive, and administrative authority in the MENA region. Furthermore, all RHQ-related activities must be carried out exclusively from within the Kingdom.

                Localization Requirements

                To ensure genuine local presence, the RHQ regime mandates:

                • Saudi residency and work permits for all RHQ personnel;
                • No hybrid or remote models from abroad;
                • Local registration of intellectual property and commercial identifiers;
                • Internal reporting and supervision obligations anchored in Saudi Arabia.

                Is RHQ Establishment Mandatory or Optional?

                While the RHQ license remains optional in principle, it is effectively mandatory for all multinational companies intending to contract with Saudi public sector entities.

                As of 1 January 2024, the Saudi government will only consider public procurement contracts from companies that have an RHQ presence in the Kingdom, unless an express exemption is granted. Companies operating purely in the private sector without government contracts remain unaffected, but will nonetheless benefit from the RHQ regime if they choose to participate.

                This regulatory shift creates a strategic filter: those seeking to participate in Saudi Arabia’s transformation across infrastructure, health, energy, and education must establish a fully embedded regional presence in the Kingdom.

                Conclusion: High-Reward, High-Compliance Environment

                The draft Rules represent a bold step in reshaping the MENA business landscape. Saudi Arabia is setting the bar high: generous tax relief and fast-track licensing are tied to substantive commitments in structure, personnel, and governance. For MNEs willing to assume regional leadership from within Saudi borders, the opportunity is as attractive as it is demanding.

                A dedicated notary account in Brazil is a legal mechanism that brings greater security, transparency, and reliability to financial transactions. Regulated under Law 8.935/1994 and Provision No. 197/2025, this service allows notaries to receive, manage, and release funds only after contractual conditions have been fulfilled. By ensuring segregation of assets, traceability, and impartial oversight, dedicated notary accounts provide an effective escrow-like solution for real estate deals, mergers and acquisitions, import/export operations, high-value asset purchases, and complex commercial contracts. This tool not only reduces legal risks and potential disputes but also strengthens trust between parties by guaranteeing that payments are safeguarded until obligations are met.

                The legal basis can be found in Law 8.935/1994, § 1 of art. 7-A, which allows notaries to receive, deposit, and manage amounts related to legal transactions, with transactions subject to objectively verifiable facts/conditions. Provision No. 197, dated June 13, 2025, regulates, at the national level, the service of notarial accounts linked to Notary Public Offices.

                Practical applications: among others, in the following transactions:

                • Real estate: guarantee that the down payment and settlement amounts will be secured in a specific account. This mitigates the risk of misappropriation of funds and ensures that the money will be released only after all contractual conditions have been met.
                • M&A: the linked notarial account creates a standardized escrow mechanism for the payment of price/holdbacks/earn-outs and conditional obligations.
                • Purchase and Sale of High-Value Movable Property: the linked account can be used to guarantee payment. The buyer deposits the amount and the seller knows that the money is safe, being released only after the transfer of ownership and delivery of the goods.
                • Import and Export: the transaction amount can be deposited with the notary and released to the exporter only after confirmation of delivery of the goods in the destination country, for example.
                • Guarantee of Obligations: In any contract that provides for the payment of a sum of money as a guarantee, the notary account can be used to provide greater security to the parties.
                • Supply, EPC/turnkey, and construction contracts: performance retentions, milestone acceptance (commissioning, as-built, issuance of ART/CREA), and payment against formal acceptance.
                • Contractual joint ventures and commercial partnerships: advances conditional on licenses, authorizations, or competitive approval, where applicable.

                Reduction of Legal Risks: The use of linked accounts reduces the chances of litigation related to lack of clarity about the origin and destination of funds. Companies can clearly demonstrate that payments were made and held by an impartial and secure institution.

                Operational structure: limited to banking entities affiliated with the CNB, which must ensure the segregation of assets, traceability through audit trails, and proof of all transactions. The authorization of the delegate requires prior accreditation and electronic registration of the essential details of the transaction and its conditions in the CNB system, with access restricted to the parties and the notary.

                Specific Purpose: amounts received as payment, guarantee, or advance payment as a result of notarial acts must be deposited in a bank account linked to the specific act and may only be moved for the purpose for which they are intended.

                Transparency and Traceability: With the linked notarial account, it is possible to clearly track the financial flow of each transaction, which increases transparency for all parties and for supervisory bodies.

                Verification of conditions and release. Once the objective conditions have been met, the notary authorizes the transfer to the recipients and files the proof of verification. In the event of a dispute between the parties, the notary suspends any movement, draws up a notarial deed, and advises on a consensual or judicial solution, without deciding on the effectiveness/termination of the transaction; if the transaction is frustrated and no solution is found, the procedure is terminated and the amounts are returned to the depositor, in accordance with the agreed clauses.

                Confidentiality and access. In transactions with a confidentiality clause, the notary public maintains confidentiality and does not issue certificates regarding the content of the transaction; documents are accessible only for correctional purposes or by court order.

                Remuneration and costs. The notary’s remuneration for the notarial account service is paid by the financial institution under the terms of the agreement, and the transfer of additional costs to the user is prohibited, without prejudice to fees for any related notarial acts.

                The Government of Vietnam has issued a new decree governing internet services and online information, which shall come into force on 25 December 2024. Decree No. 147/2024/ND-CP, promulgated on 9 November 2024, supersedes the previous Decree No. 72/2013/ND-CP and its amendments.

                This comprehensive legislation, comprising over 200 pages and 62 appended forms, addresses a wide array of internet and online topics. These include inter alia, internet services, domain names, cross-border information provision, social network services, aggregated information websites, online game services, and app store services.

                Key Provisions

                Cross-Border Information Provision

                Offshore service providers, including those offering social network and app store services on a cross-border basis, are subject to stricter requirements if they either lease data storage in Vietnam or meet a threshold of 100,000 or more total visits per month from Vietnam for six consecutive months. These providers must:

                1. Notify the Authority of Broadcasting and Electronic Information (ABEI) of their contact information
                2. Monitor and remove illegal content
                3. Store and manage user data as required
                4. Authenticate social network user accounts using Vietnamese mobile numbers or identification numbers
                5. Submit annual and ad hoc reports to the ABEI
                6. Handle user complaints

                Only cross-border providers who have notified the ABEI of their contact details may offer live stream and revenue-generating services. Non-compliance may result in blocks and penalties.

                Social Networks

                Decree 147 establishes distinct regimes for offshore and onshore social network services:

                1. Offshore providers meeting the aforementioned threshold must notify the ABEI of their contact information.
                2. Onshore providers reaching 10,000 total visits per month for six consecutive months or 1,000 regular users per month must obtain a Social Network Licence.
                3. Other onshore providers with low traffic must obtain a Notification Certificate from the ABEI.

                The decree also regulates livestream activities by stipulating conditions for social network service providers to offer livestream functions and for social network accounts to conduct livestream activities.

                Online Games

                Foreign organisations and individuals are prohibited from providing online games to service users in Vietnam on a cross-border basis. To offer such services, they must establish a local enterprise in Vietnam.

                This new decree is expected to have a significant impact on both onshore and offshore service providers in the respective fields and may tighten the regulatory landscape for internet services and online information provision in Vietnam.

                “This agreement is not just an economic opportunity. It is a political necessity.” In the current geopolitical context of growing protectionism and significant regional conflicts, Ursula von der Leyen’s statement says a lot.

                Even though there is still a long way to go before the agreement is approved internally in each bloc and comes into force, the milestone is highly significant. It took 25 years from the start of negotiations between Mercosur and the European Union to reach a consensus text. The impacts will be considerable. Together, the blocs represent a GDP of over 22 trillion dollars, and are home to over 700 million people.

                Our aim here is to highlight, in a simplified manner, the most important information about the agreement’s content and its progress, which we will update here at each stage.

                What is it?

                The agreement was signed as a trade treaty, with the main goal of reducing import and export tariffs, eliminating bureaucratic barriers, and facilitating trade between Mercosur countries and European Union members. Additionally, the pact includes commitments in areas such as sustainability, labor rights, technological cooperation, and environmental protection.

                Mercosur (Southern Common Market) is an economic bloc created in 1991 by Brazil, Argentina, Paraguay, and Uruguay. Now, Bolivia and Chile participate as associated members, accessing some trade agreements, but not fully integrated into the common market. On the other hand, the European Union, with its 27 members (20 of which have adopted the common currency), is a broader union with greater economic and social integration compared to Mercosur.

                What does the EU Mercosur agreement include?

                Trade in goods:

                • Reduction or elimination of tariffs on products traded between the blocs, such as meat, grains, fruits, automobiles, wines, and dairy products (the expected reduction will affect over 90% of the traded goods between the blocks).
                • Easier access to European high-tech and industrialized products.

                Trade in services:

                • Expands access to financial services, telecommunications, transportation, and consulting for businesses in both blocs.

                Movement of people:

                • Provides facilities for temporary visas for qualified workers, such as technology professionals and engineers, promoting talent exchange.
                • Encourages educational and cultural cooperation programs.

                Sustainability and environment:

                • Includes commitments to combat deforestation and meet the goals of the Paris Agreement on climate change.
                • Provides penalties for violations of environmental standards.

                Intellectual property and regulations:

                • Protects geographical indications for European cheese, wines, and South American coffee and cachaça.
                • Harmonizes regulatory standards to reduce bureaucracy and avoid technical barriers.

                Labor rights:

                • Commitment to decent working conditions and compliance with International Labor Organization (ILO) standards.

                Which benefits to expect?

                • Access to new markets: Mercosur companies will have easier access to the European market, which has more than 450 million consumers, while European products will become more competitive in South America.
                • Costs reduction: The elimination or reduction of tariffs could lower the prices of products such as wines, cheese, and automobiles and boost South American exports of meat, grains, and fruits.
                • Strengthened diplomatic relations: The agreement symbolizes a bridge of cooperation between two regions historically connected by cultural and economic ties.

                What’s next?

                The signing is only the first step. For the agreement to come into force, it must be ratified by both blocs, and the approval process is quite distinct between them, since Mercosur does not have a common Council or Parliament.

                In the European Union, the ratification process involves multiple institutional steps:

                • Council of the European Union: Ministers from the member states will discuss and approve the text of the agreement. This step is crucial, as each country has representation and may raise specific national concerns.
                • European Parliament: After approval by the Council, the European Parliament, composed of elected deputies, votes to ratify the agreement. The debate at this stage may include environmental, social, and economic impacts.
                • National Parliaments: In cases where the agreement affects shared competencies between the bloc and member states (such as environmental regulations), it must also be approved by the parliaments of each member country. This can be challenging, given that countries like France and Ireland have already expressed specific concerns about agricultural and environmental issues.

                In Mercosur, the approval depends on each member country:

                • National Congresses: The agreement text is submitted to the parliaments of Brazil, Argentina, Paraguay, and Uruguay. Each congress evaluates independently, and approval depends on the political majority in each country.
                • Political Context: Mercosur countries have diverse political realities. In Brazil, for example, environmental issues can spark heated debates, while in Argentina, the impact on agricultural competitiveness may be the focus of discussion.
                • Regional Coordination: Even after national approval, it is necessary to ensure that all Mercosur members ratify the agreement, as the bloc acts as a single negotiating entity.

                Stay tuned: you will find the update here as the processes advance.

                Vietnam has embraced the global minimum tax (GMT) to harmonize its tax policies with global standards. While this new tax regime is anticipated to have certain adverse effects on foreign direct investment (FDI), the Vietnamese government is devising proactive measures to mitigate these repercussions and maintain the country’s appeal as an investment haven.

                Key Ramifications of the GMT for Vietnam

                The GMT mandates multinational corporations (MNCs) with consolidated revenue surpassing €750 million to pay a minimum tax rate of 15%, irrespective of the tax rate in the country where they operate. In Vietnam, this translates to the concept of a qualified domestic minimum top-up tax (QDMTT).

                The QDMTT places an extra tax burden on foreign-invested enterprises (FIEs) that are part of an MNC, potentially deterring them from investing or expanding in Vietnam. This is particularly concerning for industries that heavily rely on tax incentives to attract FDI.

                Vietnam’s Response: Investment Support Fund and Proactive Measures

                In response to the anticipated negative impacts of the GMT, the Vietnamese government has established an investment support fund (Fund) to incentivize investments in targeted sectors. The Fund is primarily funded by proceeds from the State Budget generated by the GMT.

                Eligible enterprises for the Fund are those engaged in high-tech product manufacturing, high-tech enterprises, high-tech application projects, and enterprises with investment projects in research and development centers. Eligibility is based on capital size, annual revenue, industry, or technology utilized.

                Eligible taxpayers can receive cash subsidies for five specific expense categories:

                1. Human resource training and development
                2. Research and development expenses
                3. Fixed asset investments
                4. High-tech manufacturing expenses
                5. Social infrastructure systems

                To qualify for Fund benefits, eligible taxpayers must submit an application dossier to the Fund Office in Hanoi between August 15th and 30th of the year following the incurred Supported Expenses. Each Supported Expense category will have a distinct reimbursement ratio, and support payments will be contingent on the actual expenses incurred by eligible taxpayers.

                In addition to the Fund, the Vietnamese government is also implementing proactive measures to address the concerns of foreign investors. These measures include:

                1. Focusing on targeted industries with high growth potential that align with Vietnam’s strategic development goals
                2. Utilizing the additional revenue collected from top-up tax to enhance infrastructure and labor quality
                3. Considering cash grants for long-term qualified investments in high-tech industries

                Conclusion

                The introduction of the GMT poses challenges for Vietnam in attracting FDI. However, the government’s establishment of the investment support fund and proactive measures demonstrates its commitment to safeguarding the country’s competitiveness as an investment destination. By combining targeted support with infrastructure improvements and incentives for specific industries, Vietnam can mitigate the negative impacts of the GMT and continue to attract foreign investors.

                Summary

                Egypt aims to be Africa’s first green hydrogen producer by incentivizing companies to invest in the sector. Collaborative efforts with Germany and European companies are underway to enhance hydrogen projects and transport. Incentives include financial subsidies, tax exemptions, and administrative advantages, contingent on project conditions like commissioning, foreign funding, local materials use, and community development.

                What is the status of green energy in Egypt and what role does green hydrogen play in this?

                It is currently estimated that Egypt has the potential to generate 350 GW of wind energy and about 650 GW of solar energy per year, as per the Minister of Electricity and Renewable Energy’s (Mohamed Shaker El-Marqabi) declaration. As part of its National Climate Strategy 2050, Egypt has set itself the goal of reducing its carbon emissions, promoting the use of renewable energy sources and using alternative forms of energy, including green hydrogen. The importance the Egyptian government attaches to green hydrogen is evident, not least with the recent cabinet meeting on 17th of May 2023.

                With a view to becoming the first African country to produce green hydrogen, new incentives for green hydrogen and derivatives projects were presented at the cabinet meeting. Based on an investment of 13 billion USD, the legal and financial benefits (new incentive package) that companies in this field can benefit from in the future were presented.

                What agreements exist between Egypt and third countries to promote green hydrogen?

                Agreement between Egypt and Germany on green hydrogen

                The new incentive package was preceded by a meeting between the German-Egyptian Partnership for Green Hydrogen Projects committee and Egyptian officials on the 14th of March 2023. This resulted in a joint roadmap for supporting hydrogen production companies and promoting hydrogen transport and marketing. At this meeting, it was decided that the parties, the Egyptian Minister of International Cooperation (Rania Al-Mashat) and the Egyptian Minister of Public Enterprises (Mahmoud Esmat), will establish a platform to promote the use of green hydrogen.

                At the above-mentioned meeting, Egypt and Germany signed two Memoranda of Understanding (MoU) to enhance cooperation in the field of green hydrogen.

                The Egyptian Government also recently signed other MoUs with seven European leading companies and global alliances to produce new and renewable energy, to establish green hydrogen production complexes in Ain Al-Sokhna and the Red Sea Governorate.

                The German-Egyptian cooperation in the field of green hydrogen follows Egypt’s goal to establish itself as a hub for producing green hydrogen.

                Agreement between Egypt and third countries on green hydrogen

                Egypt has also partnered with the European Union to advance green hydrogen production. Furthermore, in 2022, on the occasion of COP27, Egypt signed a series of MoUs with several international organisations to engage foreign investment in green hydrogen production and make Egypt a transit route for clean energy to Europe.

                MoUs with global companies and alliances have defined the Red Sea Governorate as the location where green hydrogen projects will be carried out in the future.

                Are there investment incentives for the production of green hydrogen in Egypt?

                In the cabinet meeting of 17th of May 2023, the Egyptian Prime Minister Mustafa Madbuli stated that Egypt was offering the “largest” package of investment incentives and facilitations to companies wishing to invest in green hydrogen production projects in Egypt. He further announced the formation of a working group composed of representatives of the authorities involved to elaborate these investment incentives.

                The statement indicated that companies involved in green energy projects in Egypt will benefit from incentives set out in the Law drafted in the cabinet meeting of 17th of May 2023 and Investment Law No. 72 of 2017. This targets companies involved in the “production, storage and export of green hydrogen”.

                What investment incentives for the production of green hydrogen in Egypt are provided for in the draft Law of 17th of May 2023?

                Financial incentives

                Investments in the green hydrogen sector are subsidised in the amount of 33 % to 55 % of the income tax payable. The Ministry of Finance pays the subsidy within 45 days after the deadline for filing the tax return. The subsidy itself is not taxable. The exact conditions for the payment of the subsidy are still to be determined by the Cabinet.

                All machinery, equipment, materials, consumables and vehicles (except private vehicles) used in green hydrogen and derivative projects are exempt from VAT.

                No VAT is levied on exports of green hydrogen and its derivatives.

                The Ministry of Finance pays most of the duties and certification costs associated with setting up the business and all import duties on imported goods used by the establishment. Further, it pays the taxes that would have been levied on the real estate used for the activity, if any.

                Administrative incentives

                Projects in the field of green hydrogen or its derivatives benefit from the so-called golden licence, as it is called in the Investment Law No. 72 of 2017.

                All raw materials, spare parts and vehicles required for operations can be freely imported or exported directly or through distributors without the need for registration in the Importers’ Register.

                The incentives apply to projects and their extensions throughout the contract period if the project agreements are concluded within a maximum of 7 years from the date of commercial commissioning.

                Requirements

                The investment incentives apply when:

                • the project is commissioned within 5 years of the signing of the project agreement
                • at least 70 % of the investment costs come from foreign funds
                • at least 20 % of the locally used materials originate from Egypt
                • training programmes are set up for local workers and know-how is shared
                • the project company draws up a development plan for the communities in which it will operate

                What investment incentives for the production of green hydrogen in Egypt are provided for in the Investment Law No. 72 of 2017?

                The tax incentives granted under the Investment Law No. 72 of 2017 provide for special, general and additional incentives.

                Special incentives

                These are tax reductions limited to 7 years for projects that are started within 3 years (extendable to 6 years) after the provisions of the Law No. 72 of 2017 came into force (i.e. by October 2023). The investment costs consist of equity capital, long-term loans to finance the construction of the project’s movable and immovable assets, and working capital. The tax base is the taxable net profit, which is taxed at the following rates:

                1) Tax exemption on 50 % of the investment costs for the implementation of a project in geographical locations with the greatest development needs (underdeveloped locations) designated by the Central Agency for Public Mobilization and Statistics (CAPMS)

                The law identifies these sites as “Zone A”. According to the implementing regulations, “Zone A” includes:

                • the Suez Canal Economic Zone
                • the Golden Triangle Special Economic Zone
                • the New Administrative Capital Zone
                • the south of Giza province
                • the provinces of Port Said, Ismailia and Suez (east of the canal) connected to the Suez Canal.
                • border provinces, including Red Sea province south of Safaga
                • the provinces in upper Egypt
                • other areas in greatest need of development (to be determined by the Prime Minister)

                2) Tax exemption on 30 % of the investment costs of a project located in the remaining geographical areas outside “Zone A”, referred to as “Zone B”, and operating in certain sectors.

                This includes projects that:

                • are active in the field of renewable energies
                • export their products outside Egypt
                • be carried out by a small or medium-sized (SME)

                General incentives

                Parallel to the special investment incentives, general investment incentives also apply. For example, projects are exempt from certain administrative requirements and fees for a period of 5 years from the date of their registration in the commercial register. Furthermore, temporary duty-free imports and exports are possible.

                Additional incentives

                Additional investment incentives may also be granted by decision of the Council of Ministers:

                • special customs offices for the export or import of the investment project
                • bearing of the value of the utility supply (such as electricity and water supply) of the property intended for the investment project or part thereof by the State
                • partial bearing of the costs of a technical training programme for employees by the State
                • reimbursement of half of the value of the land allocated for industrial projects, provided that the activity was started within two years of the transfer of the land
                • free allocation of land for certain strategic activities
                • under certain conditions, granting of a general permit for the construction, operation and management of the project as well as for the provision of the land required for this purpose. This permit shall also be deemed to be a building permit and shall be effective in its own right without any further action being required. In December 2022, the Egyptian Cabinet granted general approval for several projects.
                • incorporation shares of capital companies subject to the Investment Law No. 72 of 2017 may be traded during the first two fiscal years of the company, subject to the approval of the competent Minister
                • simplified acquisition of real estate, provided it is used for the project

                Takeaways

                • Egypt’s Green Hydrogen Drive: Egypt is strategically embracing green hydrogen production as a pivotal element of its renewable energy vision. The country’s ambitious goals and extensive incentives underscore its commitment to becoming a leading player in the global green energy landscape.
                • International Collaborations: Collaborations with Germany and European partners highlight Egypt’s proactive approach to international cooperation in advancing green hydrogen technologies. Memoranda of Understanding and joint roadmaps are facilitating knowledge exchange and investments for robust hydrogen projects.
                • Comprehensive Incentive Framework: Egypt’s multifaceted incentive framework, including financial subsidies, tax exemptions, and administrative benefits, showcases the government’s determination to attract investments in green hydrogen production. Stringent conditions for benefiting from these incentives emphasize the nation’s dedication to sustainable practices and local community development.

                Christian Ule

                Practice areas

                • Arbitration
                • Contracts
                • Corporate
                • Distribution
                • International trade
                Contact Christian

                Contact Christian





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