Frequently Asked Questions

Under FIDIC 1999 Red Book Sub-Clause 20.1, a contractor must give notice of a claim within 28 days of becoming aware of the event giving rise to the claim, or forfeit its entitlement. UAE courts and DIAC tribunals have generally upheld this time bar strictly, meaning contractors who miss the 28-day notice period risk losing multi-million dirham extension of time and prolongation cost claims. Under FIDIC 2017, the notice period remains 28 days but the consequences are modified — the contractor loses entitlement only to the extent the Engineer or employer is prejudiced by late notice. GSDA advises contractors on implementing claim notification systems and drafting compliant notices to preserve their rights under all FIDIC forms.

Under FIDIC 1999 Sub-Clause 16.1 and FIDIC 2017 Sub-Clause 16.1, a contractor may suspend work or reduce the rate of work if the employer fails to pay certified amounts within the contractual timeframe (typically 56 days from the Engineer's certificate). The contractor must give 21 days' written notice before suspending. This right is a powerful lever in payment disputes, but improper suspension can constitute a breach. In the GCC, where government employers sometimes face budget delays, exercising suspension rights requires careful calibration. GSDA advises on exercising suspension rights correctly and negotiating payment arrangements.

Under FIDIC 1999, the Engineer makes determinations on interim payment, extensions of time, and variation valuations. These determinations are binding unless revised by a Dispute Adjudication Board or an arbitral tribunal. Under FIDIC 2017, the DAAB has replaced the DAB with a standing dispute board. Parties dissatisfied with an Engineer's determination can refer the dispute to DIAC or ICC arbitration where the tribunal conducts a full de novo review. GSDA regularly represents employers and contractors challenging or defending Engineer's determinations.

UAE arbitral tribunals and courts accept several delay analysis methodologies including as-planned vs as-built, impacted as-planned, time impact analysis, and windows analysis. The Society of Construction Law Delay and Disruption Protocol (2nd edition, 2017) is widely referenced by tribunals in the Gulf as persuasive guidance, though not binding law. Prolongation costs typically include site overheads, head office overheads (often calculated using the Emden or Hudson formulae), and financing charges. GSDA assists contractors and employers in preparing and challenging forensic delay analyses with quantum experts.

Saudi Arabia's Ministry of Municipal and Rural Affairs (MOMRA) and the Saudi Contractors Authority (SCA) have introduced contractor classification and grading requirements that determine eligibility for public projects by value and type. Foreign contractors must register with the SCA, meet Saudisation thresholds, and comply with the new construction insurance requirements introduced under the Saudi Building Code. For Vision 2030 gigaprojects, the Royal Commission for specific projects may impose bespoke regulatory requirements. GSDA advises international contractors on Saudi market entry, SCA registration, JV structuring with Saudi partners, and compliance with evolving labour and construction regulations.

Under UAE Federal Law No. 6 of 2018, a party may apply to set aside an arbitral award within 30 days on limited grounds: invalidity of the arbitration agreement, improper constitution of the tribunal, exceeding the scope of the submission, breach of due process, or the award conflicting with UAE public order. Courts do not review the merits of the award. Construction disputes with complex technical findings are generally upheld unless a clear procedural violation is demonstrated. GSDA advises on enforcement and annulment strategies for construction arbitration awards across GCC and New York Convention jurisdictions.

Under Dubai Law No. 27 of 2007 and RERA regulations, developers bear a structural defects liability of 10 years (decennial liability under UAE Civil Code Article 880). RERA requires developers to establish escrow accounts and retain a 5% defects liability deposit. Purchasers must notify defects within a reasonable time of discovery. For non-structural defects, the contractual defects notification period (DNP) in the SPA typically ranges from 12 to 24 months from handover. GSDA advises developers and purchasers on defect notification obligations and warranty enforcement.

Yes. UAE Civil Code Article 882 grants subcontractors and workers a direct action against the employer for amounts owed by the main contractor, up to the amount the employer owes to the main contractor at the time the direct action is made. This provision is mandatory and cannot be contracted out of. It is a critical protection for unpaid subcontractors on UAE infrastructure and building projects. GSDA advises subcontractors on exercising direct action rights and employers on managing exposure to dual claims.

The choice between FIDIC Red Book (employer-designed), Yellow Book (contractor-designed), Silver Book (EPC/turnkey), or Gold Book (D&B&O) depends on risk allocation preferences, project complexity and the employer's design maturity. For GCC government projects, FIDIC Red Book with heavy particular conditions remains common. For EPC energy and industrial projects, Silver Book or bespoke EPC forms dominate. NEC4 is gaining traction for collaborative projects. GSDA advises on form selection, drafts particular conditions, and benchmarks amendments against market standards — ensuring clients do not accept disproportionate risk transfer.

Standard FIDIC force majeure clauses (Sub-Clause 19 in 1999 and Sub-Clause 18 in 2017) require impossibility of performance, not mere hardship or cost increase. In the current environment — with supply chain disruption through the Red Sea, steel and cement price volatility, and regional geopolitical instability — contractors face cost escalation that falls short of force majeure. GSDA advises on drafting bespoke price escalation mechanisms, hardship clauses, and change-in-law provisions. For existing contracts, we assess whether Clause 13.8 (cost adjustments) or applicable law doctrines (UAE impossibility under Article 273 or French imprévision under Article 1195) provide relief.

Yes. Saudi Arabia's Civil Transactions Law (Royal Decree M/191 of 2023), effective June 2024, codified termination-for-breach rights, cure periods, and notice requirements for the first time. Pre-existing contracts that relied on uncodified Sharia principles or court discretion should be reviewed. Key changes include mandatory written notice of breach, a reasonable cure period before termination, and statutory rules on termination consequences including restitution and damages. GSDA advises companies with Saudi-governed contracts on conducting gap analyses and updating termination, force majeure, and remedies clauses to align with the new codification.

Under UAE Civil Code Article 390, UAE courts have broad discretion to increase or decrease agreed damages to match actual loss suffered. This means contractual liquidated damages (often called penalty clauses) are not treated as a genuine pre-estimate of loss but as a ceiling that courts may adjust. In practice, UAE courts frequently reduce inflated LD amounts and occasionally increase inadequate ones. This differs fundamentally from English law where a genuine pre-estimate is generally upheld. GSDA advises clients on structuring enforceable LD provisions, building contemporaneous evidence of actual loss, and selecting governing laws where LD certainty is critical to the deal.

The choice depends on transaction type, counterparty expectations, asset location, and enforcement forum. DIFC and ADGM law are based on English common law principles and offer access to common-law courts within the UAE — but require a genuine jurisdictional nexus. UAE federal law (Civil Code) follows a civil law tradition with mandatory provisions (e.g., Article 390 on damages, Article 246 on good faith) that override contractual terms. English law remains preferred for complex international finance. French law suits contracts with French counterparties under the reformed Code civil. GSDA advises on governing law selection considering enforceability, judicial expertise, cost, and the specific commercial risks of the transaction.

Businesses should audit force majeure and material adverse change clauses in existing contracts, assess supply chain exposure through the Strait of Hormuz and Red Sea shipping routes, review insurance coverage for war and political violence, and implement contingency sourcing arrangements. Under UAE law, force majeure requires impossibility — not mere hardship — so price escalation alone is unlikely to qualify. French law offers the doctrine of imprévision under Article 1195 allowing renegotiation for unforeseen hardship. Saudi Civil Transactions Law now codifies both force majeure and hardship. GSDA provides contractual risk audits and renegotiation support for companies affected by regional instability.

Under UAE Labour Law Article 10, non-compete clauses must be limited in time (maximum 2 years), geography, and scope of restricted activity to be enforceable. UAE courts may refuse to enforce clauses that are overly broad or cause disproportionate hardship to the employee. In commercial agreements, non-compete provisions are governed by the Civil Code and assessed for reasonableness. Enforcement remains inconsistent where the restricted scope is ambiguous or the geographic limitation is undefined. GSDA drafts narrowly tailored non-compete clauses designed to survive judicial scrutiny and advises on enforcement strategy including interim injunction applications.

Yes. UAE Federal Decree-Law No. 46 of 2021 on Electronic Transactions and Trust Services gives electronic signatures the same legal effect as wet-ink signatures for most commercial contracts. However, certain transactions are excluded — including real property transfers, powers of attorney requiring notarisation, family law documents, and negotiable instruments. The law also recognises advanced and qualified electronic signatures with higher evidentiary weight. GSDA advises on implementing compliant digital signing workflows and identifying transactions that still require wet-ink execution or notarisation.

UAE Federal Law No. 18 of 1981 (as amended) provides powerful protections to registered commercial agents. Once a commercial agency is registered with the Ministry of Economy, it cannot be terminated or not renewed without the agent's consent or a court order, even if the agency agreement contains a fixed term. De-registration requires mutual agreement or a court judgment. This creates significant lock-in risk for international brands. GSDA advises principals on structuring distribution arrangements that avoid triggering Commercial Agency Law registration — including non-exclusive arrangements, DIFC-based structures, and service agreement alternatives — and agents on protecting their registered rights.

While there is no general UAE law requiring private contracts to be in Arabic, any document submitted to UAE courts, government authorities, or notary publics must be in Arabic or accompanied by a certified Arabic translation. Crucially, where Arabic and English versions conflict, UAE courts treat the Arabic text as the authoritative version regardless of contractual language priority clauses. For contracts with DIFC or ADGM governing law and dispute resolution clauses, English is the operative language within those centres. GSDA drafts bilingual contracts with legally consistent parallel texts and manages certified translations to ensure meaning is preserved across language versions.

Under UAE Civil Code Article 273, force majeure requires impossibility of performance — mere hardship or cost increase is insufficient. Under French law (Article 1218 Code civil), force majeure similarly requires an irresistible and unforeseeable event, but the separate doctrine of imprévision (Article 1195) allows renegotiation for excessive hardship. Under English law, force majeure has no default statutory meaning and exists only as drafted in the contract. This means the clause must be precisely tailored to the governing law: UAE contracts need express hardship provisions alongside force majeure, French contracts can rely on statutory imprévision as a backstop, and English law contracts must define every trigger event exhaustively. GSDA drafts governing-law-specific force majeure and hardship frameworks.

The 2025 amendments to UAE Federal Decree-Law No. 32 of 2021 (Commercial Companies Law) introduced several significant changes: companies can now issue multiple classes of shares with different voting and economic rights, enabling preferred-share structures common in venture capital; companies can transfer registration between free zones and emirates without dissolution and re-incorporation; and a new non-profit company form has been introduced. These changes align UAE corporate law with international best practices and give companies greater structuring flexibility. GSDA advises on leveraging these new provisions for corporate restructuring.

Since the 2021 amendments to the Commercial Companies Law, foreign investors can own 100% of mainland UAE companies for most commercial activities. However, certain strategic sectors remain restricted, including oil and gas exploration, banking (subject to Central Bank licensing), insurance, and activities relating to security and defence. Individual emirates may maintain additional restrictions on specific activities. The 51% Emirati ownership requirement has been removed for most activities, but companies bidding for government contracts may still benefit from local partnership. GSDA advises on activity-specific ownership analysis and optimal structuring.

JAFZA (Jebel Ali Free Zone) is ideal for manufacturing, logistics, and physical trading with direct port access and competitive warehouse rents. DMCC (Dubai Multi Commodities Centre) is the leading free zone for commodities trading, with 25,000+ registered companies, and offers a Crypto Centre for virtual asset businesses. DIFC is a common-law financial centre regulated by the DFSA, suited to financial services, fintech, and professional services. IFZA (International Free Zone Authority) is a low-cost option for SMEs and consultancies. Each offers different licence costs (from AED 11,750 to AED 50,000+), visa allocations, and regulatory frameworks. GSDA helps clients select the optimal free zone based on their activity, staffing needs, and commercial objectives.

The Saudi Companies Law (Royal Decree M/132 of 2022), effective January 2023, eliminated the minimum capital requirement for Saudi LLCs (previously SAR 500,000 for certain activities), simplified formation procedures, and introduced new flexibility for shareholder agreements. For joint stock companies, the minimum board is 3 directors (previously 5 for listed companies). The law also permits single-shareholder LLCs and introduces statutory squeeze-out rights for majority shareholders holding 90%+ of shares. GSDA advises on Saudi entity formation, governance structuring, and capitalisation under the new regime.

Under UAE Corporate Tax Law (Federal Decree-Law No. 47 of 2022), a tax group can be formed where a UAE parent company holds 95%+ of another UAE company's shares, capital, and voting rights. Tax group members file a single consolidated return and intra-group transactions are eliminated. However, qualifying free zone persons (QFZPs) receiving the 0% rate on qualifying income cannot be included in a tax group with mainland entities. This creates planning complexity for groups operating across multiple free zones and the mainland. GSDA advises on group restructuring to optimise the interaction between grouping rules and free zone incentives.

Offshore companies registered in RAK ICC, JAFZA Offshore, or Ajman Free Zone cannot convert directly to mainland entities. The typical process involves incorporating a new mainland LLC, transferring assets, contracts, and employees, obtaining a new trade licence from the relevant Department of Economic Development, and then dissolving the offshore entity. The conversion triggers regulatory approvals, VAT registration changes, and employee transfer under the UAE Labour Law. The process typically takes 4-8 weeks. GSDA manages the full conversion process, including contractual novation and regulatory filings.

Yes. The 2025 amendments to the UAE Commercial Companies Law introduced a new non-profit company form for the first time. These entities can pursue social, cultural, educational, or environmental objectives and may generate revenue to fund their activities, but profits cannot be distributed to shareholders. This new vehicle is separate from the existing association and charity registration frameworks under Federal Law No. 2 of 2008. GSDA advises social enterprises, foundations, and international NGOs on establishing UAE non-profit entities and structuring their governance frameworks.

Under the Saudi Foreign Investment Law and MISA (now Ministry of Investment) regulations, a foreign company can register a branch in Saudi Arabia to undertake the same activities as the parent. Requirements include MISA investment licence, Ministry of Commerce commercial registration, chamber of commerce membership, Saudisation compliance from day one, and a minimum physical office presence. Branch profits are subject to 20% income tax on the foreign entity's Saudi-source income (compared to 15% zakat for Saudi-owned entities). GSDA advises on the commercial and tax implications of branch vs subsidiary structures in Saudi Arabia.

The UAE ratified the New York Convention in 2006, and UAE courts now regularly enforce foreign arbitral awards under Federal Law No. 6 of 2018. Enforcement applications are filed before the Court of Appeal, which can only refuse enforcement on limited grounds (invalidity of agreement, breach of due process, excess of jurisdiction, or conflict with UAE public order). Since the 2018 law, UAE courts have adopted a significantly more pro-enforcement stance. However, the 'public order' exception remains broadly interpreted. GSDA assists award creditors with enforcement applications and advises respondents on available defences.

DIAC (Dubai International Arbitration Centre) replaced the former DIAC and DIFC-LCIA centres following Decree No. 34 of 2021. Filing fees are calculated as a percentage of the amount in dispute, starting at AED 40,000 for claims under AED 500,000. Typical DIAC arbitration timelines range from 12 to 18 months from filing to final award for standard commercial disputes, though expedited procedures are available for lower-value claims. GSDA represents clients in DIAC arbitrations and advises on the comparative advantages of DIAC, ICC, and LCIA seats in the Gulf region.

Yes. The DIFC Courts have an established enforcement framework through the Judicial Authority Protocol and Dubai Court of Cassation decisions recognising mutual enforcement between DIFC Courts and Dubai Courts. The 'conduit jurisdiction' mechanism — where parties obtain a DIFC Court order and then enforce it through mainland courts — was curtailed by Cassation decisions but remains available in certain circumstances. DIFC Courts can also enforce directly against assets within the DIFC. GSDA advises on enforcement strategy, including selecting the optimal jurisdictional pathway for asset recovery.

Under Article 53 of Federal Law No. 6 of 2018, an annulment application must be filed within 30 days of notification of the award. Grounds include: no valid arbitration agreement, party was under legal incapacity, breach of due process (inadequate notice or inability to present case), tribunal exceeded its mandate, improper constitution, or the award conflicts with UAE public order or morality. UAE courts do not review the merits of the dispute. The annulment rate in the UAE remains relatively low, and courts have become increasingly reluctant to interfere with arbitral awards.

Under French law, the arbitration clause is autonomous from the main contract — meaning that even if the underlying contract is void, terminated, or non-existent, the arbitration clause remains valid and enforceable (Cour de Cassation, Gosset, 1963). This principle is codified in Article 1447 of the Code of Civil Procedure and is one of the most pro-arbitration doctrines in any legal system. It prevents parties from evading arbitration by challenging the validity of the main contract. GSDA relies on this principle when enforcing arbitration agreements in French-seated proceedings.

Mediation is not generally mandatory in the UAE, but certain courts and free zones have introduced pre-action mediation requirements. The DIFC Courts require parties to attempt mediation or another form of ADR before proceeding to trial (Practice Direction No. 2 of 2015). Dubai Courts have a Mediation and Conciliation Centre for civil and commercial disputes. Federal Decree-Law No. 6 of 2021 on Mediation in Civil and Commercial Disputes established a formal mediation framework, allowing court-annexed and private mediation. GSDA advises on mandatory mediation compliance and represents clients in mediation proceedings.

Under UAE Federal Arbitration Law Article 21, arbitral tribunals can order interim measures including asset preservation, evidence preservation, and orders maintaining the status quo. UAE courts can also grant interim relief in support of arbitration under Article 18. DIFC Courts have extensive interim relief powers including freezing orders, search orders, and anti-suit injunctions (modelled on English law). Emergency arbitrator procedures are available at DIAC and ICC for urgent pre-tribunal relief. GSDA advises on obtaining and enforcing interim measures in both arbitral and court proceedings.

In Gulf arbitration, tribunal-appointed and party-appointed experts are common in construction, valuation, and technical disputes. Most institutional rules (DIAC, ICC, LCIA) permit both types. The IBA Rules on the Taking of Evidence in International Arbitration (2020 revision) are widely adopted as procedural guidelines. Expert reports must comply with the expert's duty to the tribunal (not the appointing party) and are subject to cross-examination. Quantum experts typically follow RICS or AACE methodologies for construction claims. GSDA works with forensic accountants, delay analysts, and technical experts to present compelling expert evidence in Gulf arbitrations.

Under Federal Decree-Law No. 33 of 2021, an employee with over one year of service is entitled to end-of-service gratuity: 21 days' basic salary for each of the first five years, and 30 days' for each subsequent year. The total gratuity cannot exceed two years' salary. Crucially, the new law applies to all employment contracts (no more unlimited vs limited distinction for gratuity purposes) and employees who resign are entitled to full gratuity if they have served more than one year. Deductions for unpaid notice periods are permitted. GSDA advises employers on accurate gratuity calculations and disputes over final settlement amounts.

Under Ministerial Resolution No. 279 of 2022, private sector companies with 50+ employees must increase their Emirati workforce by 2% annually in skilled roles. Non-compliant companies face a monthly fine of AED 7,000 per unfilled Emirati position (increasing to AED 8,000 in 2025). Companies must also meet Emiratisation targets to access government contracts and certain licensing benefits. The government has introduced the Nafis programme to subsidise Emirati salaries and training. GSDA advises employers on compliance strategies, Emirati recruitment programmes, and defending against MOHRE enforcement actions.

No. Under UAE Labour Law Article 25, any amendment to the employment contract (including salary reduction) requires the employee's written consent. Unilateral salary cuts constitute a constructive dismissal, entitling the employee to claim arbitrary dismissal compensation of up to three months' wages plus end-of-service gratuity. During the COVID-19 period, MOHRE introduced temporary measures allowing salary reductions with employee agreement and government notification, but these were time-limited. Employers facing financial difficulty should pursue consensual restructuring, temporary leave arrangements, or redundancy processes. GSDA advises on lawful workforce cost reduction strategies.

Nitaqat is Saudi Arabia's workforce nationalisation programme administered by the Ministry of Human Resources and Social Development. Companies are classified into colour bands — Platinum, Green (High/Medium/Low), Yellow, and Red — based on their Saudisation percentage relative to their size and sector. Companies in Red and Yellow bands face restrictions on visa issuance, work permit renewals, and government contract eligibility. Quotas vary by sector: retail requires 70%+ Saudisation for certain activities, while construction has lower thresholds. GSDA advises employers on Nitaqat compliance strategies, restructuring to improve band classification, and challenging HRSD enforcement decisions.

The DIFC Employment Law (DIFC Law No. 2 of 2019) is a separate common-law regime that applies exclusively within the DIFC. Key differences include: the DIFC permits 'at-will' termination with notice (no requirement to show cause), non-compete clauses are enforceable if reasonable in scope and duration (up to 12 months post-termination), and the DIFC Small Claims Tribunal handles employment claims up to USD 500,000. UAE mainland Labour Law requires a valid reason for termination, limits non-compete to 2 years, and routes disputes through MOHRE then UAE courts. GSDA advises employers operating across both the DIFC and mainland on harmonising employment terms.

Federal Decree-Law No. 33 of 2021 introduced six employment models: full-time, part-time, temporary, flexible, remote, and job-sharing. Part-time employees accrue leave and gratuity pro rata. Flexible work allows employees to work variable hours across different days. The law also permits employees to work for multiple employers simultaneously, subject to non-compete restrictions and employer notification. Ministerial decisions have provided further detail on work permit categories for each model. GSDA advises companies on implementing flexible work policies, drafting multi-employer agreements, and managing associated compliance obligations.

Under the French Labour Code, economic redundancy (licenciement économique) requires a genuine economic cause — such as financial difficulty, technological change, or business reorganisation — and the employer must follow a strict procedural framework including consultation with the CSE (works council), individual notification, reclassification efforts within the group, and priority rehiring obligations. Severance pay is a minimum of one-quarter of a month's salary per year of service for the first 10 years and one-third thereafter. Employees with 8+ months' tenure are entitled to statutory severance. GSDA advises multinational employers on conducting French redundancy processes in compliance with the Code du Travail.

Foreign employees in Saudi Arabia require an iqama (residence permit) sponsored by their employer through the Qiwa platform. The Ministry of Human Resources issues work permits subject to Nitaqat compliance and available visa allocation. Premium residency (Saudi Green Card) allows foreign nationals to live and work independently without employer sponsorship. The SAGIA (now Ministry of Investment) investor visa enables foreign business owners to obtain residency. Recent reforms have simplified job mobility, allowing employees to transfer between employers without the previous employer's consent under certain conditions. GSDA advises employers on visa strategies, premium residency applications, and workforce compliance.

Abu Dhabi's upstream sector operates primarily through ADNOC subsidiary concession agreements, where international oil companies acquire minority interests in specific concession areas for 35-40 year terms with defined work programmes and cost-recovery mechanisms. Saudi Arabia's upstream sector is dominated by Saudi Aramco, which operates under a revised concession agreement and typically engages IOCs through service contracts and joint ventures rather than traditional concession models. ICLG's Oil & Gas 2026 edition notes significant differences in fiscal terms, local content requirements, and dispute resolution mechanisms. GSDA advises IOCs on structuring their participation in both models.

Saudi Arabia's Renewable Energy Project Development Office (REPDO), under the Ministry of Energy, manages the competitive procurement of utility-scale solar and wind projects under the National Renewable Energy Programme. IPPs are selected through competitive auctions and enter into 25-year Power Purchase Agreements with the Saudi Power Procurement Company (SPPC). The legal framework includes the Electricity Law, the Competition and Procurement Law, and REPDO-specific procurement regulations. Recent rounds have achieved record-low tariffs. GSDA advises IPP bidders and lenders on REPDO tender participation, PPA negotiation, and project finance structuring.

Green and blue hydrogen projects in the Gulf face regulatory gaps — most GCC jurisdictions lack hydrogen-specific legislation. Projects are typically structured under existing energy, environmental, and industrial licensing frameworks. Key legal considerations include water rights for electrolysis, CO₂ capture and storage regulation (for blue hydrogen), export infrastructure concessions, and certification schemes for hydrogen origin tracking (EU CertifHy and similar). The UAE Hydrogen Leadership Roadmap and Saudi NEOM green hydrogen project are driving regulatory development. GSDA advises project developers on navigating the evolving regulatory landscape and structuring hydrogen offtake agreements.

In Abu Dhabi, the Emirates Water and Electricity Company (EWEC) procures solar capacity through competitive IPP tenders under 25-30 year PPAs with take-or-pay obligations. In Dubai, DEWA procures through the Independent Power Producer model under a similar PPA framework. Both use a BOOT (Build-Own-Operate-Transfer) structure where the developer finances, constructs, and operates the plant, selling electricity at a fixed tariff. Key PPA terms include deemed generation provisions, curtailment compensation, change-in-law protections, and performance guarantees. GSDA advises IPP sponsors and lenders on PPA negotiation, risk allocation, and bankability assessment.

Saudi Arabia's In-Kingdom Total Value Add (IKTVA) programme requires oil and gas contractors to achieve progressively higher local content percentages — targeting 70% by 2027. The programme covers goods, services, and workforce Saudisation. The UAE's In-Country Value (ICV) programme, administered by the Ministry of Industry and Advanced Technology, requires ICV certification for companies bidding on ADNOC and government energy contracts. Both programmes affect procurement, subcontracting, and joint venture structuring. Non-compliance impacts scoring in competitive tenders. GSDA advises energy companies on local content compliance strategies and structuring joint ventures with local partners to meet IKTVA and ICV requirements.

UAE Federal Law No. 24 of 1999 on Environmental Protection and Development, along with emirate-level regulations (such as Abu Dhabi's Environment Agency regulations and Dubai's environmental compliance framework), impose obligations on oil and gas operators regarding emissions, waste management, spill prevention, and environmental impact assessments. Penalties include fines, licence suspension, and criminal liability for environmental damage. Offshore operations in Abu Dhabi are also subject to ADNOC's HSE framework and international standards including IOGP guidelines. GSDA advises energy companies on environmental compliance, permitting, and defending against regulatory enforcement actions.

The UAE's Net Zero 2050 strategic initiative and the establishment of the Abu Dhabi Global Market's carbon credit trading framework (AirCarbon Exchange) are reshaping energy sector contracts. New concession agreements and PPAs increasingly include carbon reporting obligations, emissions reduction targets, and carbon offset mechanisms. The UAE hosted COP28 in 2023, accelerating domestic climate regulation. Energy companies must now factor carbon pricing, methane emissions monitoring, and Scope 1-3 reporting into their contractual arrangements. GSDA advises on incorporating climate and carbon terms into energy contracts and advising on compliance with emerging UAE climate regulations.

International arbitration is the dominant dispute resolution mechanism for Gulf energy disputes, with ICC (Paris/Dubai), LCIA (London), and DIAC (Dubai) being the most common institutional choices. Most concession agreements, PPAs, and JOAs contain arbitration clauses specifying seats in Paris, London, or the DIFC. The technical complexity and value of energy disputes make arbitration preferable to local courts, which may lack specialist energy law expertise. Emergency arbitration is increasingly used for urgent interim relief in production disputes. GSDA represents energy companies in ICC and DIAC arbitrations involving concession disputes, JOA deadlocks, PPA termination, and construction claims on energy infrastructure projects.

The UAE Ministry of Economy introduced an express trademark examination service allowing applicants to obtain examination results within 5 business days (compared to the standard 6-9 month timeline). The service is available for an additional fee and applies to both national and Madrid Protocol designations. Express examination is particularly valuable for product launches, franchise agreements, and M&A transactions requiring confirmed trademark protection. ICLG Trade Marks 2026 reports this as one of the most significant developments in GCC trademark practice. GSDA utilises the express service for time-sensitive trademark filings across the UAE.

No. While the UAE, Bahrain, and Oman are members of the Madrid Protocol, Saudi Arabia, Kuwait, and Qatar are not (as of 2025). This means a single international registration under the Madrid system can designate the UAE, Bahrain, and Oman, but separate national applications must be filed in Saudi Arabia, Kuwait, and Qatar. Each GCC country has its own trademark classification system and examination standards. GCC-wide trademark harmonisation remains limited despite the 2006 GCC Trademark Law, which has not been fully implemented in all member states. GSDA files and manages trademark portfolios across all six GCC jurisdictions through a combination of Madrid designations and national filings.

The UAE does not have a standalone trade secrets law. Trade secret protection arises from a combination of Federal Penal Code provisions (Article 379 on disclosure of professional secrets), contractual confidentiality obligations, and unfair competition principles under the Commercial Code. The DIFC has more developed protection through the DIFC Intellectual Property Law (DIFC Law No. 4 of 2019), which includes specific trade secret provisions. In practice, companies must rely primarily on robust NDAs, employment contract confidentiality clauses, and IT access controls. GSDA advises on building contractual and technical trade secret protection programmes enforceable across UAE jurisdictions.

IP due diligence for Gulf-based targets covers: trademark and patent registration status across all relevant jurisdictions (often 6+ GCC countries), validity of licensing and franchise agreements, ownership chain verification (especially where IP was developed by employees or contractors), technology transfer agreements requiring government approval, and domain name portfolios. Key risks include unregistered IP rights, expired or lapsed renewals, and IP held in the personal name of founders rather than the target company. In the UAE, IP assignments must be recorded with the relevant registry to be effective against third parties. GSDA conducts IP due diligence and structures IP transfer arrangements in M&A transactions.

The GCC Patent Office (based in Riyadh) issues GCC-wide patents covering all six member states through a single application — making it one of the few functioning regional patent systems outside the EPO. Alternatively, inventors can file national applications in individual countries. The UAE also offers patents through the Ministry of Economy. PCT (Patent Cooperation Treaty) applications can designate the GCC Patent Office for regional coverage. Key considerations include: the GCC patent examination process is slower than national routes, novelty and inventive step assessments follow their own standards, and enforcement remains national. GSDA advises technology companies on optimal patent filing strategies across the Gulf.

Copyright protection in the UAE arises automatically upon creation under Federal Law No. 38 of 2021 on Copyrights and Neighbouring Rights (replacing the 2002 law). Registration with the Ministry of Economy is voluntary but provides prima facie evidence of ownership and is recommended for enforcement purposes. The law protects literary works, software, databases, films, sound recordings, and architectural designs for the author's lifetime plus 50 years. Software is protected as a literary work. The law includes fair dealing exceptions for personal use, education, and criticism. GSDA advises content creators, technology companies, and media businesses on copyright registration and enforcement in the UAE and GCC.

The UAE does not have a standalone franchise law — franchising is governed by the Commercial Agencies Law (Federal Law No. 18 of 1981), the Commercial Code, and contractual terms. Registering a franchise as a commercial agency provides strong agent protection but creates termination lock-in risks for the franchisor. Saudi Arabia requires franchisors to register with the Ministry of Commerce and submit the franchise disclosure document (FDD) before offering franchises. The Saudi Franchise Law imposes pre-contractual disclosure obligations and mandates Arabic-language agreements. GSDA advises international brands on structuring franchise arrangements that comply with local registration requirements while preserving franchisor flexibility.

Current UAE and GCC IP law does not explicitly address AI-generated works or inventions. Under the UAE Copyright Law (Federal Law No. 38 of 2021), copyright requires a human author, creating uncertainty about the protectability of purely AI-generated content. For patents, the GCC Patent Office and UAE Ministry of Economy have not yet addressed whether an AI system can be named as an inventor (consistent with the global trend following the DABUS cases). Companies using AI in creative and inventive processes should structure their workflows to ensure meaningful human contribution and should protect AI training data and models through trade secret and contractual mechanisms. GSDA advises technology companies on IP strategies for AI-generated outputs in the absence of specific legislation.

No — for most commercial activities. The 2021 amendments to the Commercial Companies Law removed the general requirement for 51% Emirati ownership in mainland LLCs. However, certain strategic activities still require local partnership, including activities related to national security and some regulated sectors. Additionally, companies seeking certain government contracts or licence categories may benefit from having a local partner even when not legally required. The practical choice between 100% foreign ownership and a local partnership depends on market access, government relationships, and sector-specific requirements. GSDA advises on structuring JVs that optimise local partnership value while protecting the foreign investor's interests.

Effective deadlock mechanisms in Gulf JVs typically include: escalation to senior management (CEO-level negotiation period of 30-60 days), mediation before an agreed institution (DIAC or ICC), 'Russian roulette' or 'Texas shoot-out' buy-sell mechanisms, and ultimately dissolution or arbitration. The choice depends on the parties' relative bargaining power and exit appetite. In the Gulf, cultural factors often favour extended negotiation and mediation over adversarial mechanisms. Courts in the UAE can dissolve JV entities on deadlock grounds under the Commercial Companies Law, but this is a last resort. GSDA designs bespoke deadlock resolution cascades tailored to the specific commercial relationship and local business culture.

IP contributions to cross-border JVs require: independent valuation by a qualified IP valuer (often using discounted cash flow or relief-from-royalty methods), a detailed IP licence agreement specifying scope, territory, exclusivity, and royalty terms, clear provisions on improvements and derivative IP developed during the JV, and registration of IP assignments or licences in each relevant jurisdiction. In the Gulf, IP licences must be registered with trademark and patent offices to be effective against third parties. Tax considerations include transfer pricing compliance and withholding tax on royalty payments. GSDA structures IP contribution and licensing arrangements that protect the contributing party's rights while enabling the JV to operate effectively.

In Saudi Arabia, incorporated JVs (joint stock companies or LLCs) are subject to corporate income tax: 20% on the foreign partner's share of profits and 2.5% zakat on the Saudi partner's share. Contractual JVs (unincorporated) are treated as transparent for Saudi tax purposes, with each party taxed on its share according to its own tax status. Withholding tax of 5-20% applies to certain cross-border payments. The choice between corporate and contractual JV structures significantly affects overall tax efficiency, and the new Transfer Pricing Bylaws (aligned with OECD BEPS) impose arm's-length pricing on related-party transactions within JV structures. GSDA advises on tax-efficient JV structuring in coordination with specialist tax advisors.

JVs operating in Saudi Arabia are subject to the Nitaqat Saudisation framework, requiring minimum percentages of Saudi employees based on sector, company size, and band classification. JVs in the oil and gas sector must also comply with IKTVA (In-Kingdom Total Value Add) local content requirements targeting 70% by 2027. Government procurement contracts require JVs to demonstrate local content commitments. Additionally, JVs with government or semi-government partners may face specific localisation obligations in their JV agreements. Non-compliance affects visa allocation, work permit renewals, and eligibility for government contracts. GSDA advises JVs on structuring compliance with Saudisation and local content requirements from formation onwards.

Most Gulf JV agreements contain restrictions on transfer: pre-emption rights (right of first offer or refusal), consent requirements (unanimous board or partner approval), tag-along and drag-along rights, and change-of-control provisions triggered by indirect transfers of shares in the parent company. Under UAE law, LLC share transfers require a notarised agreement and registration with the Department of Economic Development. Transfer restrictions are strictly enforced. Poorly drafted change-of-control clauses may fail to capture indirect transfers through parent company sales, creating unintended consequences. GSDA drafts comprehensive transfer and change-of-control provisions and advises on exit structuring for JV interests.

A JV typically involves creating a new entity (incorporated JV) with shared equity, profits, losses, and governance, while a consortium is a contractual arrangement where each party performs a defined scope of work independently without forming a new entity. For Gulf infrastructure projects, the choice affects: joint and several liability (consortium members are often jointly and severally liable to the employer), tax treatment (transparent vs opaque), bonding and guarantee requirements, and risk allocation. Employers on major projects (roads, metro, utilities) often prefer consortium arrangements because they can look to each consortium member individually. GSDA advises on structuring both JV and consortium arrangements for public and private infrastructure projects.

Minority JV partners in the Gulf should negotiate: reserved matter vetoes (covering share capital changes, related-party transactions, annual budgets, key appointments, material contracts, and distribution policy), board representation disproportionate to shareholding, information and audit rights, anti-dilution protection, put option rights triggered by specific events (including deadlock), and quarterly reporting obligations. Under UAE law, LLC members can agree on enhanced minority protections in the memorandum of association and a separate shareholders' agreement. The MOA protections are enforceable against third parties, while the SHA is binding only between the parties. GSDA drafts layered minority protection frameworks using both the MOA and a parallel SHA.

The UAE introduced federal competition and merger control through Federal Law No. 4 of 2012 on the Regulation of Competition (as amended). The Competition Regulation Committee (CRC) must approve mergers, acquisitions, and joint ventures that meet the notification thresholds. The DIFC and ADGM have separate competition frameworks for transactions involving DIFC or ADGM entities. Additionally, sector-specific regulators — CBUAE for banks and insurance, SCA for listed companies, TRA for telecom — must approve transactions in regulated sectors. Failure to obtain required approvals can result in fines and transaction unwinding. GSDA advises on multi-regulator filing strategies for UAE M&A transactions.

UAE SPAs typically include: representations and warranties covering title, financial statements, material contracts, compliance, and litigation; indemnities for specific identified risks; a locked-box or completion accounts mechanism for pricing adjustment; conditions precedent (regulatory approvals, third-party consents, material adverse change); restrictive covenants on the seller (non-compete, non-solicitation); and warranty and indemnity insurance is increasingly common for larger transactions. Escrow arrangements are used for deferred consideration and warranty claims. Under UAE law, the contractual warranties regime operates alongside the Civil Code's provisions on defects (hidden defects in the sold thing). GSDA structures SPAs that address both common-law-style warranty protections and UAE Civil Code requirements.

Saudi Arabia presents several unique due diligence considerations: zakat liability exposure (2.5% annual assessment on the Saudi partner's share of net worth), which can generate significant historical liabilities; Saudisation compliance and Nitaqat band status; government contract dependencies and IKTVA local content obligations; Sharia compliance of financing arrangements; real property ownership restrictions for non-Saudi entities in Mecca and Medina; and the new Competition Law filing requirements. Additionally, the Saudi Civil Transactions Law (effective June 2024) has changed the legal framework for contractual representations and termination rights. GSDA conducts targeted due diligence for Saudi acquisitions addressing these jurisdiction-specific risks.

Foreign ownership limits for UAE-listed companies vary by company and are set in the articles of association (typically 49% but increasingly raised to 100%). The SCA Takeover and Acquisition Rules require a mandatory tender offer when an acquirer (alone or in concert) reaches 30% of voting rights in a listed company. The tender offer must be for all remaining shares at the highest price paid by the acquirer in the preceding 12 months. Listed company acquisitions also require SCA approval, and the acquirer must engage an SCA-licensed financial advisor. ADX and DFM have separate listing rules that may impose additional requirements. GSDA advises strategic and financial buyers on public M&A transactions in the UAE.

The Saudi Competition Law (Royal Decree M/25 of 2014) and the General Authority for Competition (GAC) Implementing Regulations require pre-completion merger notification when combined revenues of the parties exceed SAR 100 million or the target's revenues exceed SAR 40 million. Notification is suspensory — the transaction cannot close before GAC clearance. Review periods are 90 days (Phase I) extendable by 90 days (Phase II). GAC can prohibit transactions that substantially lessen competition. Failure to notify carries fines of up to 10% of annual revenues. Gun-jumping (premature implementation) is separately sanctionable. GSDA advises on Saudi competition filings and structuring transactions to address GAC concerns.

Family businesses represent over 80% of GCC private sector companies. Acquisition-specific challenges include: complex ownership structures (often held through individuals rather than holding companies), limited financial transparency and reliance on audited accounts that may not reflect full economic activity, personal guarantees by family members securing company debts, intermingled personal and company assets, undocumented related-party transactions, and succession planning considerations. Cultural factors — including the seller's continued involvement post-completion and sensitivity around disclosure — require careful management. GSDA has extensive experience advising private equity firms and strategic buyers on acquiring Gulf family businesses, including structuring earn-out and transition arrangements.

A typical UAE M&A transaction timeline from letter of intent to closing is 3-6 months for mid-market deals. Key stages include: LOI and exclusivity negotiation (1-2 weeks), legal and financial due diligence (4-8 weeks), SPA negotiation and execution (3-6 weeks), regulatory approvals (CRC competition clearance takes 30-90 days, sector-specific approvals vary), completion mechanics including DED transfer and notarisation (1-2 weeks). Larger transactions involving listed companies, regulated sectors, or multiple jurisdictions can take 6-12 months. Delays commonly arise from regulatory approval timelines, third-party consent requirements, and working around UAE public holidays. GSDA manages transaction timetables and coordinates with all advisors to maintain deal momentum.

W&I insurance has become increasingly available and common in Gulf M&A transactions, particularly for deals above USD 50 million. The policy provides the buyer with recourse against an insurer (rather than the seller) for losses arising from breach of the seller's warranties. This is particularly valuable in competitive auction processes where sellers demand clean exits, and for PE fund sellers with limited-life vehicles. Key considerations include: coverage limitations (known risks and specific indemnities are typically excluded), policy excess (usually 0.5-1% of enterprise value), premium costs (1.5-3% of policy limit), and the requirement for thorough buyer due diligence. GSDA coordinates W&I insurance placement with specialist brokers and structures SPAs to work effectively alongside the policy.

Yes. Under Dubai Law No. 7 of 2006 on Real Property Registration, non-GCC foreign nationals can own freehold property in designated areas approved by the Ruler. Major designated freehold areas include Dubai Marina, Downtown Dubai, Palm Jumeirah, JBR, Business Bay, DIFC, and Dubai Hills Estate. Outside designated areas, foreigners can acquire leasehold interests of up to 99 years. Off-plan purchases are regulated by RERA (Law No. 13 of 2008), which requires developer registration, escrow accounts, and project completion guarantees. GSDA advises international investors on Dubai property acquisitions, RERA compliance, and structuring to optimise ownership and exit options.

Abu Dhabi Law No. 19 of 2005 allows non-UAE nationals to own freehold in designated investment zones (such as Saadiyat Island, Yas Island, and Al Reem Island). Outside these zones, foreigners can acquire musataha (surface rights for up to 50 years) or usufruct (right to use for up to 99 years). Freehold ownership is registered with the Abu Dhabi Department of Municipalities and Transport (DMT) and grants full ownership rights including the right to sell, mortgage, and inherit. Usufruct rights are more limited — the holder can use and derive income from the property but does not own the land. GSDA advises on the appropriate ownership structure based on the investor's objectives and the property's designated zone status.

Saudi Arabia's Real Estate Ownership for Non-Saudis Regulations (Royal Decree M/15 of 2000) historically restricted foreign ownership to property required for licensed business activities. Recent reforms under Vision 2030 — including the Premium Residency system and MISA investment licence framework — have significantly expanded foreign ownership rights. Premium residency holders can own residential property throughout Saudi Arabia (except Mecca and Medina). The draft Real Estate Ownership Law aims to further liberalise the market. Commercial property ownership requires a MISA investment licence and minimum investment thresholds. GSDA advises foreign investors on Saudi property acquisition strategies under the evolving regulatory framework.

Under Dubai Law No. 8 of 2007 and RERA regulations, developers selling off-plan property must deposit all buyer payments into a designated escrow account held by an approved escrow agent. Funds can only be released to the developer upon achieving certified construction milestones. RERA monitors escrow accounts and can freeze developer accounts for non-compliance. Developers must also register projects with RERA and obtain a no-objection certificate before marketing. For buyers, the escrow system provides protection against developer default — if the project is cancelled, buyers are entitled to a refund from the escrow account. GSDA advises buyers on escrow protection and developers on RERA project registration and compliance.

UAE REITs are regulated by the SCA (Securities and Commodities Authority) under Resolution No. 6 of 2019 on REITs. They must distribute at least 80% of net income, invest primarily in income-generating real estate, and be managed by an SCA-licensed fund manager. Saudi REITs are regulated by the CMA (Capital Market Authority) under the Real Estate Investment Funds Regulations — Saudi Arabia has the largest REIT market in the MENA region with listed REITs on Tadawul. Saudi REITs must distribute at least 90% of net income. Both jurisdictions offer tax efficiencies: UAE REITs benefit from the general absence of income tax (pre-corporate tax for non-qualifying income), while Saudi REITs benefit from zakat exemptions on the fund level. GSDA advises on REIT structuring, CMA/SCA licensing, and portfolio acquisitions.

Dubai has a dedicated Rental Disputes Centre (RDC) established under Decree No. 26 of 2013, which has exclusive jurisdiction over landlord-tenant disputes in Dubai (excluding DIFC). The RDC handles rent increase disputes, eviction cases, maintenance obligations, and security deposit claims. Proceedings are relatively fast (typically 2-4 months) and cost-effective compared to Dubai Courts. Appeals go to a Rental Disputes Appeal Tribunal. Rent increases are governed by the RERA Rental Index (Decree No. 43 of 2013). DIFC tenancies are governed by DIFC Leasing Law and disputes are heard by DIFC Courts. GSDA represents landlords and tenants before the RDC and advises on lease structuring to avoid common disputes.

Hotel management agreements (HMAs) in the Gulf are typically structured as long-term agreements (15-25 years with renewal options) between a hotel owner and an international operator (Marriott, Hilton, Accor, IHG). Key terms include: management fees (base fee of 2-3% of gross revenue plus incentive fee of 8-10% of adjusted GOP), operator performance tests (which the owner can use to terminate for underperformance), FF&E reserve contributions (typically 3-5% of gross revenue), brand standards compliance, and operator non-compete provisions. Gulf hotel owners increasingly negotiate for tighter performance tests, shorter initial terms, and greater owner approval rights over budgets and key personnel. GSDA advises hotel owners and operators on HMA negotiation and disputes.

Dubai Law No. 27 of 2007 on Jointly Owned Property established the strata title system for multi-unit buildings and mixed-use developments. Each unit has a separate title deed, and common areas are owned jointly by all owners according to their participation percentages. An owners' association (OA) must be established for each development, governed by the Jointly Owned Property Directions (RERA). Common issues include: service charge disputes (charges must reflect actual costs and be approved by RERA), developer-controlled OAs that operate in the developer's rather than owners' interests, inadequate maintenance of common areas, and disputes over the use of common areas. GSDA advises owners, developers, and OA management companies on strata title issues and OA governance disputes.

France's Law No. 2016-1691 (Sapin II) requires French companies with 500+ employees and EUR 100 million+ revenue to implement comprehensive anti-corruption compliance programmes including: a code of conduct, internal whistleblowing mechanism, risk mapping, third-party due diligence, accounting controls, training, disciplinary sanctions, and an internal monitoring system. The Agence Française Anticorruption (AFA) audits compliance. Sapin II has extraterritorial application — it applies to French companies' activities worldwide and can reach non-French companies with a sufficient nexus to France. Penalties include fines up to EUR 1 million for individuals and EUR 5 million for companies, plus court-supervised compliance programmes. GSDA advises French and international companies on Sapin II compliance programme implementation and AFA audit preparation.

Companies operating in the GCC face a complex multi-layered sanctions environment: UN Security Council sanctions (implemented domestically by each GCC state), US OFAC sanctions (which have extraterritorial reach through the USD clearing system and secondary sanctions), EU sanctions, and local GCC sanctions (including the 2017-2021 Saudi-led sanctions on Qatar). The UAE has its own sanctions committee under Federal Decree-Law No. 20 of 2018. The DIFC and ADGM have separate sanctions compliance frameworks. Companies must screen counterparties against all applicable lists, implement robust sanctions policies, and ensure that correspondent banking relationships are not disrupted. GSDA advises multinational companies on implementing integrated sanctions compliance programmes covering all applicable regimes.

The UAE's Personal Data Protection Law (Federal Decree-Law No. 45 of 2021) and its implementing regulations establish a comprehensive data protection framework. Key obligations include: lawful processing basis (consent or legitimate interests), data subject rights (access, rectification, erasure, portability), data protection impact assessments for high-risk processing, mandatory data breach notification, and restrictions on cross-border data transfers (adequacy decisions or appropriate safeguards). The PDPL closely mirrors GDPR but with some differences — including a broader range of lawful processing bases, different breach notification timelines, and separate regimes for the DIFC (Data Protection Law 2020) and ADGM (Data Protection Regulations 2021). GSDA advises companies on PDPL compliance, cross-border data transfer mechanisms, and interaction with GDPR.

Saudi Arabia's Personal Data Protection Law (Royal Decree M/19 of 2021, amended 2023) came into full effect in September 2023, with a transitional compliance period until September 2024. Key requirements include: explicit consent for processing personal data (with limited exceptions), appointment of a Data Protection Officer for certain entities, data localisation requirements (personal data must be stored in Saudi Arabia unless cross-border transfer conditions are met), data breach notification to the SDAIA (Saudi Data and Artificial Intelligence Authority) within 72 hours, and data subject rights including access, correction, and deletion. Penalties include fines up to SAR 5 million and imprisonment for certain violations. GSDA advises companies on Saudi PDPL compliance programmes and cross-border data transfer assessments.

Listed companies on ADX and DFM must comply with SCA Governance Rules (Resolution No. 3 of 2020), which mandate: independent directors (at least one-third of the board), audit and nomination/remuneration committees with independent majorities, annual corporate governance reports, related-party transaction approval procedures, insider trading controls, and quarterly and annual financial reporting. DIFC-incorporated listed entities follow DFSA Listing Rules and the DIFC Companies Law. The SCA governance framework aligns with international best practices but includes jurisdiction-specific elements such as Emirati board representation requirements and specific UAE disclosure obligations. GSDA advises listed companies on governance compliance, board formation, and regulatory reporting.

VARA (established by Dubai Law No. 4 of 2022) is the world's first independent virtual asset regulator. VARA licences virtual asset service providers (VASPs) operating in Dubai (excluding the DIFC, which is regulated by the DFSA). Licence categories include: exchange services, broker-dealer services, custody services, lending/borrowing services, and payment/remittance services using virtual assets. VASPs must comply with AML/CTF requirements, minimum capital adequacy, client asset segregation, and technology governance standards. VARA has enforcement powers including fines and licence revocation. GSDA advises virtual asset businesses on VARA licensing applications, compliance programme design, and ongoing regulatory obligations.

Whistleblower protection in the GCC is developing but remains less comprehensive than in Europe or the US. The UAE DIFC has specific whistleblower protection under DFSA regulations for reports of financial services misconduct. The UAE Federal Government introduced whistleblower protection provisions in the anti-corruption framework under Federal Decree-Law No. 11 of 2021. Saudi Arabia's Reporting Protection Regulations provide protection for persons who report corruption, money laundering, and terrorism financing. However, standalone whistleblower protection legislation comparable to the EU Whistleblower Directive or US SOX is not yet in place in most GCC jurisdictions. GSDA advises companies on implementing whistleblower channels and policies that meet multi-jurisdictional requirements including Sapin II and US SOX where applicable.

ESG reporting requirements are rapidly expanding across the GCC. The UAE's ADX and DFM have introduced voluntary ESG disclosure guidance aligned with GRI and SASB standards, with mandatory sustainability reporting expected for listed companies. Saudi Arabia's Tadawul published ESG Disclosure Guidelines requiring listed companies to report on material ESG metrics. The UAE's Net Zero 2050 strategy and Saudi Arabia's Saudi Green Initiative are driving additional sector-specific sustainability obligations. DIFC and ADGM have introduced sustainable finance frameworks. The ISSB (International Sustainability Standards Board) standards (IFRS S1 and S2) are expected to be adopted across the GCC. GSDA advises companies on ESG compliance frameworks, sustainability reporting, and integrating ESG considerations into corporate governance structures.

The choice depends on your risk allocation preference. The Red Book suits projects where the employer provides the design; the Yellow Book shifts design responsibility to the contractor; the Silver Book creates full turnkey risk. We advise on which form best suits your commercial objectives and how to draft particular conditions that modify the general conditions appropriately.

We use forensic delay analysis methodologies — typically windows analysis or time impact analysis — working alongside programming experts to isolate the causes of delay, establish concurrent delay, and quantify prolongation costs. In multi-contract environments, we also address interface delays and the allocation of responsibility between contract packages.

Yes. Our dispute resolution team regularly represents clients in arbitrations administered by the ICC, DIAC, LCIA, and CRCICA. We handle the full arbitration lifecycle from notice of dispute through to award enforcement, including emergency arbitrator applications and interim measures.

We advise clients engaged in Saudi Arabia's giga-projects and broader Vision 2030 infrastructure programme. Our Riyadh office provides on-the-ground support for regulatory compliance, labour law, and procurement, while our broader team handles contract structuring and dispute resolution.

We analyse CAR/EAR policy wordings, assess coverage triggers, and manage the claims notification process. Where coverage is disputed, we represent policyholders or insurers in coverage litigation or arbitration, working with loss adjusters and forensic accountants to establish the quantum of insured losses.

We leverage the New York Convention framework and local enforcement procedures in each relevant jurisdiction. Our presence in France, the UAE, Saudi Arabia, and Egypt allows us to manage enforcement proceedings directly rather than instructing local counsel on your behalf.

Yes. We advise on LEED, BREEAM, and Estidama certification requirements as they affect contract drafting, specification compliance, and liability for failure to achieve sustainability targets. This is increasingly relevant for projects in the UAE and Saudi Arabia.

We structure incorporated and unincorporated joint ventures for construction projects, addressing profit-sharing, management control, liability allocation, deadlock resolution, and exit mechanisms. Our joint ventures practice works closely with our construction team to ensure JV agreements align with the underlying construction contracts.

Yes. We apply for urgent injunctive relief to prevent unjustified on-demand bond calls. The legal threshold varies by jurisdiction — in the UAE, we must demonstrate fraud or unconscionability; in France, the standard is abus manifeste. We act quickly because bond calls can be irreversible once the bank pays out.

Key areas include: payment terms (pay-when-paid vs pay-when-certified), liability caps, indemnities, insurance requirements, variation procedures, and dispute resolution mechanisms. We ensure that obligations flowing down from the main contract are matched by corresponding rights and that no 'gap' risks exist.

We analyse the contractual payment mechanism, verify compliance with notice requirements, and pursue recovery through the most effective route — whether that is contractual adjudication, statutory payment proceedings, or arbitration. We also advise on suspension rights where payment is wrongfully withheld.

Yes. We represent contractors and employers before FIDIC Dispute Adjudication Boards, prepare referrals and responses, and advise on the binding nature of DAB decisions and the procedures for challenging them in subsequent arbitration.

We pursue retention release claims by establishing that the contractual preconditions have been met, challenging the employer's or main contractor's basis for withholding, and enforcing release through the applicable dispute resolution mechanism.

Our team handles contractor and supplier disputes across France, the UAE (all emirates), Saudi Arabia, Qatar, Bahrain, Kuwait, Oman, and Egypt. Our multi-office structure means we can manage proceedings locally rather than relying on correspondent firms.

We advise contractors and suppliers on their options when a counterparty becomes insolvent — including security of payment claims, retention of title, step-in rights, and the impact of insolvency on arbitration proceedings and bond obligations.

We analyse the employer's requirements, the contractor's proposals, and the contractual hierarchy of documents to determine what falls within the original scope and what constitutes a compensable variation. This analysis is often central to the largest claims on design-and-build projects.

We advise both. Our experience includes representing host governments and NOCs in concession negotiations, as well as advising IOCs and service companies on the same transactions. This dual perspective gives us insight into both sides of the negotiating table.

Yes. Our dispute resolution team has experience with investment treaty arbitrations, ICC arbitrations, and ad hoc proceedings arising from concession disputes, including stabilisation clause claims, expropriation allegations, and fiscal regime changes.

We advise drilling contractors, well services companies, and integrated service providers on their master service agreements, call-off contracts, liability and indemnity regimes, and disputes with operators.

We have advised on projects in Abu Dhabi, Saudi Arabia, Qatar, Kuwait, Oman, and Bahrain, including upstream concessions, offshore facility construction, refinery expansions, and gas processing plant disputes.

We advise on the impact of US, EU, and UK sanctions on energy transactions, including trade restrictions, financing limitations, and the practical implications for personnel deployment and technology transfer.

We structure JVs for exploration and production, pipeline development, LNG terminals, and petrochemical projects. Our approach integrates corporate structuring, regulatory compliance, and the underlying operational agreements.

Yes. We advise on gas price review mechanisms, take-or-pay disputes, and the arbitration of pricing disagreements under long-term gas sales agreements.

We advise on the contractual allocation of decommissioning costs, regulatory requirements for site remediation, and the structuring of decommissioning security arrangements across multiple jurisdictions.

Yes. We advise on utility-scale solar PV, concentrated solar power, and onshore wind projects in Saudi Arabia, the UAE, Oman, and Egypt. Our work includes project structuring, PPA negotiation, EPC contracting, and regulatory compliance.

We advise on green bond issuances, sustainability-linked loans, and project finance structures that comply with EU Taxonomy requirements and regional green financing frameworks. We work with lenders, developers, and ESG rating agencies.

We have negotiated government-backed PPAs under competitive auction programmes in Saudi Arabia and the UAE, as well as corporate PPAs for industrial consumers seeking to secure renewable energy supply for manufacturing and data centre operations.

Yes. We represent developers, EPC contractors, and investors in disputes arising from construction delays, technology underperformance, subsidy changes, and PPA termination. Our dispute resolution team has specific experience with energy sector arbitrations.

We are advising clients on the emerging legal and regulatory frameworks for green hydrogen production, including electrolyser procurement contracts, hydrogen offtake agreements, and the infrastructure rights required for hydrogen transport and storage.

We advise government authorities on the design of renewable energy auction mechanisms, concession agreements, and the legal frameworks for independent power producer programmes.

We advise on the contractual structuring of co-located solar-plus-storage projects, standalone battery energy storage systems, and the grid connection and dispatch agreements specific to storage technologies.

We manage the environmental impact assessment and permitting process across European and Middle Eastern jurisdictions, coordinating with local environmental consultants and regulatory authorities to secure approvals within project timelines.

Yes. We represent acquirers, sellers, management teams, and financial advisors on transactions across both sides. This dual perspective allows us to anticipate counterparty positions and structure transactions more effectively.

We work with Islamic finance advisors and Sharia boards to structure acquisition financing that complies with Sharia principles while meeting the commercial and security requirements of the transaction. This includes murabaha, musharaka, and commodity murabaha structures.

We have advised on acquisitions, joint ventures, and capital market transactions in Saudi Arabia, including MISA approval processes, Saudi Competition Authority filings, and Tadawul-listed company transactions. Our Riyadh office provides on-the-ground support.

We advise distressed businesses, creditor committees, and investors on formal and informal restructuring processes across European and Middle Eastern jurisdictions, including French safeguard proceedings, UAE bankruptcy law procedures, and out-of-court workouts.

We conduct legal due diligence across all jurisdictions where we operate — France, the UAE, Saudi Arabia, Qatar, Bahrain, Kuwait, Oman, and Egypt — providing a unified risk assessment rather than fragmented local reports.

We draft earn-out provisions with clear definitions, objective metrics, robust accounting standards references, and dispute resolution mechanisms designed to minimise post-completion disagreements. Where disputes arise, we represent clients in earn-out claims.

We advise sovereign wealth funds, government investment vehicles, and family offices on direct investments, co-investments, and fund commitments across Europe and the Middle East.

We coordinate multi-jurisdictional antitrust filings, including French ADLC, Saudi GAC, and UAE Competition Committee submissions, managing timelines and conditions to avoid delays to transaction completion.

Yes. We manage the end-to-end licensing process, including regulatory business plan preparation, application drafting, correspondence with the regulator, and post-authorisation compliance setup.

We advise on the structuring of Sharia-compliant financial products, including murabaha, wakala, ijara, and sukuk, ensuring compliance with both Sharia standards and conventional regulatory requirements.

We represent financial institutions at all stages of regulatory investigations — from initial information requests through to formal enforcement proceedings, settlement negotiations, and appeals.

We advise fintech startups and scale-ups on regulatory classification, licensing requirements, partnership structuring with licensed institutions, and the legal frameworks for payments, lending, and investment services.

We design AML/CFT compliance programmes that satisfy the requirements of multiple regulators, including risk assessment methodologies, customer due diligence procedures, transaction monitoring, and suspicious activity reporting.

We advise on the establishment and structuring of investment funds across European and Middle Eastern jurisdictions, including UCITS, AIFs, DIFC funds, and ADGM funds, as well as fund distribution arrangements.

We advise international banks on the regulatory and operational requirements for establishing branches and representative offices in France, the UAE, Saudi Arabia, and other jurisdictions where we operate.

We advise insurance companies on licensing, solvency requirements, policyholder protection regulations, and distribution compliance across European and Middle Eastern insurance markets.

Yes. We represent sovereign states in ICSID, UNCITRAL, and SCC investment treaty proceedings. Our experience includes defending claims based on expropriation, fair and equitable treatment, full protection and security, and umbrella clause obligations.

We advise government authorities on the legal and contractual framework for PPP programmes, including enabling legislation, model concession agreements, risk allocation matrices, government support mechanisms, and dispute resolution procedures.

We advise SWFs on investment governance, deal structuring, co-investment arrangements, and the legal aspects of direct investments across infrastructure, real estate, and operating businesses in Europe and the Middle East.

We design procurement processes, draft tender documents, establish evaluation criteria, and advise on the management of procurement challenges and protests, ensuring compliance with applicable transparency and competition requirements.

We advise governments on the design and implementation of foreign investment screening mechanisms, including the assessment of national security implications, the definition of strategic sectors, and the processing of investment notifications.

We have advised government ministries, public works authorities, and sovereign investment vehicles in Saudi Arabia, the UAE, Qatar, Bahrain, Kuwait, and Oman on a range of matters including infrastructure procurement, regulatory reform, and international arbitration.

We assist government authorities with the drafting and implementation of new legal and regulatory frameworks, including comparative analysis of international best practice, stakeholder consultation, and transitional implementation support.

We advise on the application of sovereign immunity doctrines in commercial transactions, arbitration proceedings, and enforcement actions, including the distinction between sovereign and commercial acts under the laws of relevant jurisdictions.

We act for both — policyholders pursuing claims, insurers defending coverage positions, brokers facing negligence allegations, and reinsurers managing treaty disputes. This dual perspective gives us insight into both sides of insurance disputes.

We have extensive experience with CAR/EAR claims on major construction projects. We assess coverage, manage the claims notification process, and represent our clients in coverage disputes with insurers or in subrogated recovery actions against third parties.

We advise on the structuring of Sharia-compliant insurance products, including takaful operator governance, participant fund management, and the resolution of disputes arising under takaful contracts.

Yes. Our multi-jurisdictional presence allows us to manage insurance disputes involving policies placed in London, losses occurring in the Gulf, and proceedings in European or Middle Eastern courts and arbitral tribunals.

We advise insurers, reinsurers, and intermediaries on regulatory licensing, solvency requirements, and conduct of business compliance across French, DIFC, and Saudi regulatory frameworks.

We represent both brokers defending negligence claims and policyholders pursuing brokers for failures in coverage placement, risk disclosure, or claims handling advice.

We advise on D&O policy terms, coverage triggers, defence cost advancement, and allocation disputes between insured directors, their companies, and D&O insurers.

We act in reinsurance disputes involving follow-the-settlements obligations, treaty interpretation, aggregation, and the allocation of losses between cedants and reinsurers under treaty and facultative arrangements.

Both. We advise sponsors on fund formation, deal execution, and exits, and we provide ongoing legal support to portfolio companies on commercial, employment, and transactional matters during the hold period.

Yes. We manage LBO execution across France, the UAE, Saudi Arabia, and other jurisdictions where we operate — coordinating SPA negotiation, debt documentation, regulatory filings, and completion mechanics as a single integrated workstream.

We design sweet equity, ratchet, and co-investment arrangements that incentivise management while maintaining tax efficiency under French, English, and Middle Eastern tax regimes.

We regularly advise on transactions involving Gulf sovereign wealth funds, family offices, and institutional investors as co-investors alongside European PE sponsors. We understand their governance expectations, Sharia considerations, and decision-making processes.

We advise sponsors on fund establishment across European and Gulf jurisdictions, including LP terms, carried interest structuring, co-investment mechanics, and regulatory compliance for fund managers.

We manage the full secondary buyout exit process — vendor due diligence, SPA negotiation, W&I insurance, management re-investment arrangements, and regulatory clearances.

We advise portfolio companies on bolt-on acquisitions that complement the sponsor's buy-and-build strategy, handling due diligence, transaction execution, and integration across multiple jurisdictions.

We advise sponsors on distressed and special situations investments, including non-performing loan acquisitions, pre-pack sale processes, and restructuring-led buyouts.

The enforceability of non-compete clauses varies significantly across Gulf jurisdictions. In the UAE, non-competes are enforceable if reasonable in scope and duration under the new labour law. In Saudi Arabia, enforcement is more limited. We advise on drafting covenants that maximise enforceability in each relevant jurisdiction.

We advise on partnership and LLP disputes, including profit-sharing disagreements, expulsion proceedings, retirement terms, and the valuation and division of partnership assets. We prioritise discreet resolution to protect the firm's reputation.

We draft engagement letters, master services agreements, and terms of business that appropriately limit your liability, define the scope of your services, and include appropriate dispute resolution and governing law provisions.

We defend professional services firms against negligence claims from clients, managing the claims process, coordinating with PI insurers, and representing firms in litigation or arbitration proceedings.

We advise on the employment law implications of operating teams across multiple jurisdictions — including secondment structures, local hiring requirements, posted worker obligations, and the coordination of employment terms across offices.

We advise on the protection of proprietary methodologies, frameworks, and databases through contractual provisions, employment agreement IP clauses, and formal IP registration where appropriate.

We advise on the legal structuring of professional services mergers, including partner integration, goodwill allocation, client relationship transfer, and the harmonisation of partnership terms and governance.

We implement GDPR and Gulf data protection compliance programmes tailored to professional services firms, including client data handling, cross-border transfer mechanisms, and breach response procedures.

We advise on freehold and leasehold acquisitions across all UAE emirates, including title due diligence, RERA compliance, escrow arrangements, and the structuring of holding vehicles for foreign investors.

We advise international investors on Saudi real estate investments, including NEOM, the Red Sea Project, and other Vision 2030 developments. Our Riyadh office provides on-the-ground support for regulatory approvals and transaction execution.

We advise on conventional and Sharia-compliant real estate financing, including mortgage structuring, project finance for developments, and the security packages required by lenders across European and Gulf jurisdictions.

We negotiate commercial leases for office, retail, and industrial premises across France, the UAE, and Saudi Arabia, advising on rent structures, break options, fit-out contributions, and the differing tenant protection regimes in each jurisdiction.

We provide end-to-end legal support for development projects — from land acquisition and planning permission through construction procurement, project finance, and unit sales or lease-up.

We represent clients in landlord-tenant disputes, construction defect claims, title disputes, and forced sale proceedings across European and Middle Eastern courts and arbitral tribunals.

We advise on the establishment and structuring of real estate funds and REITs across European and Gulf jurisdictions, including regulatory approvals, investor terms, and fund governance.

We advise on the legal structuring of mixed-use developments and hospitality projects, including hotel management agreements, branded residence structures, and the coordination of multiple use classes within a single development.

Our Paris office advises on corporate M&A, international arbitration, real estate transactions, construction law, employment restructuring, intellectual property, regulatory compliance, and banking & finance. We handle both domestic French matters and cross-border transactions involving the Middle East and North Africa.

Yes. Our Paris-based avocats are fully qualified members of the Paris Bar and have rights of audience before all French courts, including the Tribunal de Commerce, the Tribunal Judiciaire, the Paris Court of Appeal, and the Cour de Cassation. We also represent clients in ICC and ad hoc arbitration proceedings seated in Paris.

Paris is the coordination centre for all GSDA cross-border mandates. When a matter spans multiple jurisdictions, our Paris partners lead the engagement and coordinate with our offices in Dubai, Riyadh, Doha, Cairo, and other locations to ensure consistent legal strategy and seamless execution.

Our Paris team operates in French, English, and Arabic. All key documents and advice can be delivered in any of these languages. For matters involving Gulf counterparties or tribunals, our bilingual capability eliminates the communication barriers that often slow cross-border transactions.

International arbitration is a core strength of our Paris practice. We represent clients in ICC arbitration proceedings — the most common form of international commercial arbitration — as well as proceedings under ICSID, UNCITRAL, and other institutional rules. Our Paris location, minutes from the ICC, is a strategic advantage.

We offer senior-led, partner-involved service on every matter — not the leverage model of large international firms where junior associates handle the day-to-day work. Our unique differentiator is the depth of our Middle Eastern practice integrated with top-tier French legal expertise, enabling us to bridge transactions that other Paris firms cannot.

We regularly advise multinational clients on French employment restructurings, including PSE procedures, collective redundancy processes, works council consultations, and the negotiation of ruptures conventionnelles collectives. Our team understands both the legal framework and the practical dynamics of French labour relations.

This is one of our most distinctive capabilities. We advise Gulf sovereign wealth funds, family offices, and corporate investors on acquisitions of French businesses, navigating foreign investment screening (Décret Montebourg), French corporate law, tax structuring, and post-acquisition governance.

Our Grenoble office serves semiconductor manufacturers, cleantech and energy companies, software firms, biotech companies, advanced manufacturing groups, and the startups and scale-ups that emerge from Grenoble's research ecosystem. We also advise international corporations with R&D operations in the region, including technology companies and industrial groups.

Yes. IP protection is central to our Grenoble practice. We advise on patent strategy, technology licensing, trade secret protection, and IP disputes for companies in the semiconductor, cleantech, software, and biotech sectors. For matters requiring proceedings before the Tribunal Judiciaire de Paris (which has exclusive jurisdiction for certain IP disputes), we coordinate with our Paris office.

Employment law is a core practice area in Grenoble, where international technology companies regularly recruit expatriate engineers and researchers. We advise on employment contracts, stock plans, non-compete clauses, works council consultations, and restructurings under French labour law.

Gulf sovereign wealth funds and technology investors are increasingly interested in Grenoble's deep-tech ecosystem. Our Grenoble office connects directly to our Dubai, Riyadh, and Doha offices, enabling us to facilitate investment, joint ventures, and technology licensing arrangements between Gulf entities and Grenoble-based companies.

Our Grenoble-based avocats are qualified members of the Barreau de Grenoble with rights of audience before the Tribunal de Commerce, Tribunal Judiciaire, Cour d'appel de Grenoble, and the local Conseil de Prud'hommes. We also represent clients in arbitration and mediation proceedings.

Grenoble is one of the three largest micro- and nanotechnology centres in the world, alongside clusters in New York State and Taiwan. The city hosts 40,000 technology jobs, four international research facilities (ESRF, ILL, EMBL, IRAM), the CEA-LETI laboratory, and the Minatec campus. It has been called the 'Silicon Valley française' and holds the French Tech label.

Our Grenoble office provides local legal services within the Auvergne-Rhône-Alpes region, with particular expertise in technology, IP, and innovation-economy legal issues. Paris serves as our global coordination centre for cross-border mandates. The two offices work together seamlessly, with Grenoble providing regional expertise and Paris providing access to national institutions, ICC arbitration, and international regulatory bodies.

Yes. Grenoble is a national leader in energy transition, hosting the Tenerrdis competitiveness cluster and companies like Symbio (hydrogen fuel cells) and Air Liquide's research centre. We advise on project development agreements, regulatory approvals, power purchase contracts, and the structuring of renewable energy investments.

Our Marseille office advises on maritime and port law, commercial real estate, construction and procurement, energy and infrastructure, Euro-Mediterranean trade and investment, employment law, corporate transactions, and dispute resolution. We handle both domestic French matters and cross-border transactions involving North Africa, the Gulf, and sub-Saharan Africa.

Maritime and port law is a core practice area of our Marseille office. We advise on charterparty disputes, cargo claims, marine insurance, ship arrest, port concessions, and regulatory matters related to France's largest commercial port. Our avocats appear before the Tribunal de Commerce de Marseille, which handles a significant volume of maritime disputes.

We advise developers, investors, and contractors involved in Euroméditerranée — one of southern Europe's largest urban renewal operations. Our work covers commercial real estate acquisitions, development agreements, construction contracts, planning approvals, and the structuring of public-private partnerships within the Euroméditerranée perimeter.

This is one of our Marseille office's most distinctive capabilities. Marseille has deep historic, commercial, and cultural ties to Algeria, Tunisia, and Morocco. We advise on cross-Mediterranean joint ventures, acquisitions, distribution agreements, and investment structures — leveraging our Marseille presence alongside our offices in Dubai, Riyadh, and Cairo for mandates spanning Europe, North Africa, and the Gulf.

Our Marseille team operates in French, English, and Arabic — reflecting the trilingual nature of Euro-Mediterranean business. Many of our Marseille avocats also have working proficiency in Maghrebi Arabic dialects, which facilitates direct communication with counterparties and clients in Algeria, Tunisia, and Morocco.

Marseille and Paris are connected by a 3-hour TGV service, enabling seamless coordination. Our Marseille office handles regional matters independently while partnering with Paris on cross-border mandates, ICC arbitration, and matters requiring engagement with national regulatory bodies such as the AMF, Autorité de la Concurrence, and CNIL.

Yes. Marseille is France's leading centre for petroleum refining and a strategic Mediterranean energy hub. We advise on project finance, LNG terminal operations, pipeline agreements, renewable energy developments, and environmental regulatory compliance for energy infrastructure projects in the region.

The Luminy technopole hosts world-class immunology and microbiology research centres (INSERM, CNRS, CIML). We advise biotech companies and research institutions on IP protection, technology licensing, clinical trial agreements, and the structuring of public-private research collaborations under French and EU state-aid rules.

Our Dubai office advises on real estate and construction, corporate structuring and M&A, banking and finance, employment law, technology regulation, energy contracts, and dispute resolution — under both UAE onshore law and the DIFC common-law framework. We handle domestic UAE matters and cross-border transactions involving the Gulf, Europe, and North Africa.

Yes. Our lawyers practise in both the UAE onshore system (Dubai Courts) and the DIFC common-law system (DIFC Courts). This dual capability is essential in Dubai, where many commercial transactions involve entities, contracts, or assets that touch both jurisdictions. We also represent clients in DIAC arbitration and ad hoc proceedings.

Real estate is a core practice area. We advise on off-plan and resale purchases, portfolio transactions, developer agreements, RERA compliance, DLD registration, escrow arrangements, and the resolution of real estate disputes. Our work covers freehold, leasehold, and usufruct properties across mainland Dubai and free zones.

We advise on DIFC entity formation, licensing applications, DFSA regulatory compliance, fund structuring, and corporate governance under the DIFC Companies Law. For businesses requiring both a DIFC and onshore presence, we structure the dual-entity arrangement and advise on the regulatory obligations of each.

Our Dubai office works closely with our Paris headquarters, which is only a 7-hour direct flight away. This connection is essential for the significant volume of Franco-Gulf and Euro-Gulf commercial activity — French companies expanding to Dubai, Gulf entities acquiring European assets, and cross-border disputes that require coordinated legal strategy across jurisdictions.

Construction dispute resolution is one of our strongest capabilities in Dubai. We handle FIDIC-based claims, delay and disruption proceedings, defect liability disputes, and payment recovery actions in DIAC arbitration, ad hoc arbitration, and the Dubai Courts. Our Paris-trained civil-law perspective enhances our approach to the UAE's civil-code construction law framework.

Our Dubai team operates in English, Arabic, and French. English is the dominant language for DIFC matters and international commercial transactions. Arabic is required for Dubai Courts proceedings and government regulatory filings. French serves our Francophone African and French corporate clients who use Dubai as their Middle East gateway.

We advise businesses on compliance with the UAE corporate tax regime introduced in 2023, including taxable income calculations, free zone qualifying income provisions, transfer pricing requirements, and the interaction between corporate tax obligations and existing free zone incentives. We work with specialist tax advisors to deliver integrated structuring advice.

Our Riyadh office advises on giga-project construction contracts, corporate structuring and M&A, capital markets and sukuk, energy and natural resources, technology regulation, employment and Saudisation, and dispute resolution before the Saudi courts and in SCCA arbitration. We serve international contractors, investors, financial institutions, and technology companies operating in the Kingdom.

Giga-project advisory is a core strength of our Riyadh practice. We advise contractors, JV partners, and subcontractors on NEOM, The Red Sea, Qiddiya, Diriyah Gate, and other major programmes — covering procurement bids, FIDIC and Government Tenders Law contract negotiation, claims management, and dispute resolution.

We represent clients before the Saudi Commercial Courts, the Board of Grievances (for government contract disputes), and the Labour Courts. We also conduct arbitration proceedings under SCCA rules. Our understanding of both the new codified civil law and the remaining Sharia-based principles ensures effective advocacy in Saudi proceedings.

We advise international businesses on the MISA foreign investment licensing process, including entity formation, the Regional Headquarters Programme (requiring multinationals to establish in Riyadh), sector-specific licensing requirements, and ongoing regulatory compliance. We also advise on joint ventures with Saudi partners where local participation is required.

The Paris-Riyadh corridor is one of our most active cross-border relationships. French industrial groups, luxury brands, construction companies, and defence firms are major participants in the Saudi economy. Our dual presence enables coordinated legal strategy for transactions and disputes that span both jurisdictions, including French foreign investment screening for Saudi acquisitions in France.

We advise on IPOs and secondary offerings on Tadawul, sukuk issuances, fund formation, and CMA regulatory compliance. Our capital markets practice serves issuers, financial institutions, and investors navigating Saudi Arabia's rapidly developing securities regulation — the most sophisticated capital market regulatory framework in the Gulf.

Yes. We advise employers on Nitaqat compliance (workforce nationalisation quotas), the reformed Saudi Labour Law, employment contract drafting, termination procedures, end-of-service benefit calculations, and Labour Court dispute resolution. For international companies, we also advise on the structuring of secondment and managed-service arrangements.

The Civil Transactions Law (2023) is Saudi Arabia's first comprehensive civil code — 721 articles codifying contract law, tort, and property rights that were previously governed by uncodified Sharia principles. This is the most significant legal reform in Saudi history, creating a predictable, statute-based commercial law framework. Our team advises clients on how this new code affects their existing and future contractual relationships.

Our Doha office advises on energy and LNG contracts, construction and infrastructure, banking and finance, corporate structuring, real estate, technology regulation, and dispute resolution — under both onshore Qatari law and the QFC common-law framework. We serve energy companies, EPC contractors, financial institutions, and corporate clients operating in Qatar.

Energy and LNG advisory is a core capability of our Doha practice. We advise on EPC contracts, joint venture agreements, offtake arrangements, and service contracts related to Qatar's North Field Expansion — the world's largest LNG project. We also handle construction claims and disputes arising from energy infrastructure projects.

Yes. We advise on QFC entity formation, QFCRA regulatory compliance, and dispute resolution before the QFC Civil and Commercial Court (QICDRC). For clients with both onshore and QFC operations, we manage the interaction between the two systems to ensure consistent corporate governance and regulatory compliance.

We represent clients before the Qatari courts (Court of First Instance and Court of Appeal) and in arbitration proceedings under QICCA and QICDRC rules. For international disputes, we also handle proceedings under ICC, LCIA, and ad hoc rules where the seat or subject matter involves Qatar.

Our Paris headquarters provides the European connection essential for the significant French and European commercial presence in Qatar. TotalEnergies, Vinci, Bouygues, and other French companies are major participants in Qatar's economy. We coordinate cross-border legal strategy for transactions and disputes spanning Qatar and Europe.

Construction dispute resolution is a core strength. Qatar's massive infrastructure programme generates complex claims involving delay, disruption, variation, and defects. We represent contractors, subcontractors, and project owners in QICCA arbitration, QICDRC proceedings, and the Qatari courts.

We advise international companies on the MOCI licensing process, foreign ownership structures (including the sectors where 100% foreign ownership is permitted), joint venture arrangements with Qatari partners, and the QFC licensing alternative. We also advise Qatari entities, including QIA, on outbound investment transactions.

Our Doha team operates in Arabic, English, and French. Arabic is essential for onshore court proceedings and government regulatory filings. English is the primary language for QFC matters and international commercial transactions. French serves our TotalEnergies, Vinci, and other French and Francophone clients operating in Qatar.

Our Manama office advises on Islamic finance and banking, financial services regulation, fintech licensing, insurance and takaful, corporate structuring, real estate, industrial contracts, and dispute resolution under Bahraini law. We serve financial institutions, sovereign entities, fintech companies, and international businesses operating in Bahrain.

Islamic finance is a core specialty of our Manama practice. We advise on sukuk, murabaha, ijara, istisna, wakala, and takaful products — ensuring compliance with AAOIFI Sharia standards, CBB regulatory requirements, and international commercial documentation expectations. Bahrain's position as the global centre of Islamic finance standard-setting makes our Manama office the natural base for this practice.

Yes. We advise fintech companies on CBB regulatory sandbox applications, full licensing processes, open banking compliance, and crypto-asset regulation. Bahrain's CBB was the first Gulf regulator to launch a fintech sandbox, and the Kingdom's progressive approach has attracted a growing cluster of digital finance companies.

We represent clients before the Bahraini Civil Courts and in BCDR-AAA arbitration proceedings — one of the Gulf's most well-regarded arbitration institutions, established in partnership with the American Arbitration Association. We also handle mediation and conciliation proceedings under BCDR-AAA rules.

Bahrain permits 100% foreign ownership in most sectors without requiring a local partner — one of the most liberal regimes in the Gulf. We advise on company formation, MOIC registration, and the specific structuring considerations for foreign-owned entities, including holding companies and regional headquarters operations.

The King Fahd Causeway creates deep economic integration between Saudi Arabia and Bahrain, with over 60,000 vehicles crossing daily. Our Manama and Riyadh offices coordinate on corporate structuring, joint ventures, and transactions that span both jurisdictions — a common pattern for financial institutions and industrial companies operating across the causeway.

The Accounting and Auditing Organization for Islamic Financial Institutions (AAOIFI) is headquartered in Manama and sets the global Sharia standards for Islamic finance. AAOIFI standards are adopted by regulators across the Gulf, Southeast Asia, and other Islamic finance markets. Our understanding of AAOIFI standards is essential for structuring Sharia-compliant products that will be accepted across multiple jurisdictions.

We advise on CBB licensing for conventional insurance and takaful companies, regulatory compliance, reinsurance arrangements, policy disputes, and the structuring of takaful products under AAOIFI standards. Bahrain is a significant regional insurance hub, and the CBB's unified regulatory framework covers both conventional and Islamic insurance.

Our Kuwait City office advises on oil and gas contracts, construction and infrastructure, PPP transactions, banking and finance, corporate structuring, real estate, and dispute resolution under Kuwaiti law. We serve international energy companies, EPC contractors, financial institutions, and corporate clients operating in Kuwait.

Yes. Kuwait Petroleum Corporation contract advisory is a core capability. We advise on the procurement framework governing KPC and its subsidiaries (KNPC, KOC, KOTC, PIC, KUFPEC), covering bid preparation, contract negotiation, variation claims, and the distinctive compliance requirements — including Kuwaitisation and local content obligations.

We advise on KAPP public-private partnership transactions — from initial procurement through financial close to operational disputes. Kuwait's PPP programme covers power generation, water desalination, waste management, and social infrastructure, and the KAPP regulatory framework has specific requirements that sponsors and contractors must carefully navigate.

We represent clients before the Kuwaiti Commercial Courts and in KCAC arbitration proceedings. Kuwait's approach to enforcement of arbitral awards and its procedural requirements for court proceedings have distinctive features that require experienced local practice knowledge.

Our Kuwait City office coordinates with our Dubai hub for GCC-wide mandates, Riyadh for northern Gulf cross-border transactions, Doha for Qatar-Kuwait matters, and Paris headquarters for European companies operating in Kuwait. This network enables seamless multi-jurisdictional legal support across the Gulf and Europe.

We advise on the KDIPA foreign investment licensing process, company formation (WLL, KSC), joint ventures with Kuwaiti partners, and the sector-specific foreign ownership restrictions. KDIPA permits up to 100% foreign ownership in approved sectors, subject to compliance with Kuwaitisation requirements and other conditions.

The KIA, established in 1953, is the world's oldest sovereign wealth fund with estimated assets exceeding US$900 billion. As a major global institutional investor, KIA drives significant cross-border M&A and investment activity. Our firm advises on the legal aspects of transactions involving Kuwaiti sovereign and institutional investors.

Yes. Kuwait's infrastructure programme generates complex construction disputes involving delay, disruption, variation, and payment claims. We advise contractors and employers on both preventive claims management during project execution and formal dispute resolution through the Kuwaiti courts and KCAC arbitration.

Our Muscat office advises on energy and green hydrogen projects, Duqm SEZ matters, logistics and maritime, construction and infrastructure, tourism and hospitality, mining, corporate structuring, and dispute resolution under Omani law. We serve energy companies, contractors, logistics operators, and corporate clients operating in the Sultanate.

Green hydrogen is a core emerging practice area for our Muscat office. Oman's commitment to producing 1 million tonnes of green hydrogen by 2030 is generating a new wave of joint venture, EPC, and project finance work. We advise on the legal structuring, contracting, and regulatory compliance for these pioneering projects.

Yes. We advise investors, contractors, and operators on all aspects of the Duqm SEZ — SEZAD licensing, land lease agreements, construction contracts, the zone's tax incentive framework, and the specific regulatory and dispute resolution mechanisms within the zone.

We represent clients before the Omani Commercial Courts and in OCAC arbitration proceedings. Oman's judicial system has specific procedural requirements, and our local practice knowledge ensures effective dispute resolution strategy from the outset.

Our Muscat office coordinates with our Dubai hub for GCC-wide mandates, our other Gulf offices for cross-border transactions, and our Paris headquarters for European companies operating in Oman. This network is particularly valuable for energy and infrastructure clients with operations spanning multiple Gulf states.

We advise on the MOCIIP registration process and the amended Foreign Capital Investment Law, which now permits 100% foreign ownership in most sectors. We also advise on the specific structuring considerations for companies operating in Oman's free zones (Sohar, Salalah) and the Duqm Special Economic Zone.

Omanisation is the Sultanate's workforce nationalisation programme, setting specific quotas for Omani nationals by sector. We advise employers on compliance strategies, the Ministry of Labour's enforcement approach, and the structuring of employment arrangements that satisfy Omanisation requirements while maintaining operational effectiveness.

Yes. Oman's strategic position along Indian Ocean shipping lanes — with ports that bypass the Strait of Hormuz — drives a significant logistics and maritime practice. We advise on port concession agreements, shipping contracts, free zone licensing, and the regulatory framework governing Asyad Group and the Ministry of Transport.

Our Cairo office advises on real estate and new city development, construction and infrastructure, energy (hydrocarbons, solar, wind, nuclear), banking and finance, corporate structuring and M&A, and dispute resolution — including CRCICA arbitration and Egyptian Economic Court litigation. We serve international investors, contractors, financial institutions, and corporate clients in MENA's largest market.

Yes. The New Administrative Capital is one of the largest urban development projects in the world. We advise international developers, contractors, and investors on development agreements, construction contracts, NUCA regulatory compliance, and the structuring of investments in this transformative project.

CRCICA arbitration is a core capability of our Cairo practice. The Cairo Regional Centre for International Commercial Arbitration is the most established arbitration institution in Africa and the Arab world, and we have deep experience representing clients in proceedings under CRCICA's UNCITRAL-based rules.

We represent clients before the Egyptian Economic Courts, Commercial Courts, and Court of Cassation. Egypt's judiciary is the most developed in the Arab world, with extensive published jurisprudence. Our local practice knowledge ensures effective advocacy across commercial, construction, corporate, and regulatory disputes.

Egypt's legal system was built on French civil-law principles — the Civil Code of 1948 reflects this heritage directly. Our Paris-headquartered firm brings a natural affinity with Egyptian legal reasoning. Additionally, France is one of the largest European investors in Egypt, and our dual presence supports the significant French corporate presence in the country.

We advise on SCZone licensing, land allocation agreements, construction contracts, customs and tax incentive frameworks, and the specific regulatory regime governing companies in the zone. The SCZone is attracting international manufacturers and logistics operators seeking to leverage Egypt's position on global trade routes.

Egypt's energy practice is diversified — hydrocarbons (Zohr gas field, West Nile Delta), solar (Benban), wind (Gulf of Suez), and nuclear (El Dabaa). We advise on project structuring, EPC contracts, power purchase agreements, regulatory compliance, and dispute resolution for energy projects across all fuel types.

Gulf-Egypt cross-border investment is a significant practice area. Emirati, Saudi, and Qatari sovereign and private capital flows heavily into Egyptian real estate, infrastructure, and financial services — including the Ras el-Hekma mega-development. Our Cairo office, combined with our six Gulf offices, provides coordinated legal support for these transactions.