Tax and Emerging Technologies Lawyer
Dhanalakshmi Pillai Perumal
Bachelor in Bank Management, Bachelor of Law (India), Adv. Masters in International Taxation (the Netherlands)
Key areas of expertise
Data Privacy, Property, Financial Services and International Tax
Contact: +968 9732 0342
Experience and Expertise
Dhana admitted into the Bar of Tamilnadu (India) in 2005, is an International Tax lawyer specialized in Data Privacy, real estate development project and financial services. Dhana qualified from the International Tax Centre, The Netherlands in 2007 worked with Deloitte Rotterdam office for 3years and moved to Deloitte Muscat for 1year. At Deloitte, Dhana was responsible for tax compliance, tax accounting and representation before the tax authorities. In 2013, Dhana joined Dentons Muscat office and advised on Waterfront real estate development project, corporate, and tax matters.
Between 2016-2017 Dhana worked with the tourism arm of Oman government, Omran, where she was responsible for producing the tax efficient legal structure, drafting changes to the special laws and rules applicable to Mina Al Sultan Qaboos Waterfront Development, and dealing with the ministries for the taking-over of the port operations by Omran. Dhana is a specialist in dealing with state owned enterprises and regulatory bodies working and negotiating contracts for and with government and is currently working with Al Hashmi Law. Dhana is advising a large real estate development after assisting in the restructuring of the group in 2019.
Dhana has developed an area of expertise once after having an opportunity to draft and advising Oman’s National Data Strategy and Oman’s National (digital) Addressing Law. Due to the unique nature of law and tax combination, Dhana has constantly expanded her field of expertise. Dhana regularly writes and speaks on webinars on Privacy and Data Protection law on LexisNexis and on corporate tax laws and VAT.
Dhana would like to further her legal career in the emerging technologies, data ethics, privacy and protection. Dhana is producing a white paper to an Oman Public authority on regulatory foundation for sandboxes that will let innovation labs/ hubs to test out new, technology-led services.
Al Hashmi Law, Head of Property, Tax and Project Finance March 2017 – Present
· Structuring and advising an international Mezzanine Financing of SMEs in Oman involving a corpus of USD 500 million and preparing documentation for the structure.
· Advising National Centre for Statistics and Information on the National Data Strategy for Oman and framing the same for them.
· Advising and assisting National Centre for Statistics and Information in its entire tender policy manual, finalizing all related contracts and contract management for E-Census 2020 project.
· Advising restructuring of the Grand Blue City real estate project and is negotiating and finalizing the transactional and financial contracts.
· Advising on REIT (and I-REITs) on its suitability, structuring, drafting PPMs and setting it up with the fund managers and listing.
· Advising Al Shumookh Investment Fund in its $50 million Phase I Real Estate Investment Fund involving government ministry properties.
· Advising an Integrated Tourism Project in Duqm and negotiating amendments to the usufruct land rights and the development agreement for the project developer with the Special Economic Zone Authority of Duqm.
· Advising on many tax cases until assessment order, dealing with the tax authority at the objection stage and representations before tax committee and primary court. Some of the international clients on tax includes, Grupo TSK, Grupo Tradebe, FTI Group.
· Preparing JV/ consortium agreements for international bidders for real estate development project tenders that aim at Public Private Partnership.
· Advising on ICV and PFD under the international tenders and dealing with OAPFD for a Singapore based client.
· Reviewing and finalizing FIDIC based consultancy contracts, analysing and summarising the risks and liabilities under the contracts, preparing claim notices, legal opinions etc for Disenos Y Proyectos Reunidos SA, Teejan, and many other clients.
· Advising Chedi (Hotels Management Company SAOG) in revising its Corporate Governance Policies and amending the articles following the coming into force of the new Commercial Companies Law.
· Advising and assisting a State Owned Enterprise Grand Blue City Development SAOC in drafting the Corporate Governance Manual in line with the new Commercial Companies Law.
· Drafting and negotiating Development Agreement with the Ministry of Tourism.
· Drafting of all land rights’ transfer agreements and arranging for registrations under the Integrated Tourism Complex (ITC) projects.
· Advising on international tax treaties, Oman corporate tax and withholding tax and filing objections against assessments and tax cases before the tax committee.
· Advising on VAT and Customs duty.
· Manages a team of 3 lawyers – interested in guiding and training the junior lawyers.
Oman Tourism Development Company SAOC, Legal Consultant July 2016-Feb 2017
· Reviewing and finalising legal structure for Mina Al Sultan Qaboos waterfront ITC project.
· Reviewing the due diligence report of the land acquired from Ministry of Transport and Communications.
· Reviewing Development Agreement for the project.
· Drafting and reviewing all agreements and documents connected with the project.
· Reviewing of all shipping and allied services agreements and special laws and rules connected with the operation of the Mina Al Sultan Qaboos Port where the project is currently planned.
· Drafting and reviewing of Hotel Management Agreements, Operator Agreement, etc.
· Managing the commercial contracts entered in by all subsidiaries and setting standards and rules with regard to important clauses in the contracts such as change in control, sovereign guarantee, termination, demobilization, governing law, etc that may adversely affect OMRAN.
· Drafting and reviewing of legal section in the tender documents – Request for Proposal.
· Advising on ICV and PFD under the international tenders and dealing with OAPFD.
· Reviewing and finalizing FIDIC based construction contracts.
· Incorporation on Limited Liability Companies/ Joint Stock companies.
· Advising on board reserved matters and board meetings/ shareholder reserved matters and general meetings.
· Advising on reduction of share capital, acquisition of companies from Ministry of Finance, share sale and transfers, reorganization of asset management company structures.
Dentons Muscat, Associate Jan 2013- June 2016
· Advising on taxation of foreign companies in Oman for ‚doing business‘ – IDP Education, JP Morgan, Fresenius Medical Care, Parsons Brinkerhoff, 3M, Navitas English, Petrospec.
· Advising on withholding tax and other tax technical questions – Salalah port Services, Raytheon, KCA Deutag Drilling Company LLC, DHL GBS Services.
· Customs duty exemption application and duty free zone works – Concrete Solutions LLC, Duqm Crushers LLC, ATU.
· Tax committee appeals and cases before court of first instance – HSBC, COWI Larsen, MB Petroleum.
· Legal opinion on appeal of a tax case – Al Ahlia Insurance.
· Incorporation on Limited Liability Companies/ Joint Stock companies – EADS Airbus, Concrete Solutions LLC, PSA Marine.
· Advice on branch registrations of Foreign Companies – Total, BP, Daelim, BAE, Bechtel.
· Advice on buyback/ board meeting/ general meetings – DHL GBS Services, Salalah Port Services, EADS Airbus, UMW, GE, Brookfield.
· Review of commercial contracts – For major clients such as Sohar Cereals, Sembcorp, Sumitomu, Saud Bahwan; on secondment to Oman Air.
· Acquisition of shares – Oman International Group, Duqm Crushers LLC, Al Tammam Ferrochrome, Electricity Holding Company.
Deloitte Muscat, Manager June 2009 – Feb 2011
· Advising on tax technical topics such as seconded employees, management fees, profits earned through offshore drilling ships, withholding taxes, head office expense deductions, group loan interest deductions.
· Corporate restructuring with tax efficiencies – many clients.
· Tax litigations – many clients including Omantel before the tax committee.
· Claiming tax exemption under tax returns – Muriya Tourism ITC project.
· Various advices on tax treaty interpretation and claiming tax treaty benefits.
Deloitte Bangalore, Deputy Manager Feb 2009 – May 2009
· Group restructuring involving US companies.
· Advising on tax efficient cash repatriations and other international tax planning on inbound and outbound investments for investors in IT/ ITES Sector in India.
Deloitte Rotterdam, International Tax Law Analyst June 2007 – Jan 2009
· Advise on tax technical topics such as participation exemption, thin capitalisation, inter-company transactions, tax base erosion, tax loss carry over, tax provision, group taxation to clients such as Boliden BV, Atmel BV, Leaf BV, DHL BV and many others.
· Tax due diligence for De Ruiter BV that was acquired by Monsanto US Corp.
· Advice on tax treaty interpretation, international tax planning opportunities through Netherlands for clients in mining Industries and real estate.
· Advice on European Community tax directives.
International Tax Center, Leiden, the Netherlands 2006 to 2007
Adv. Masters in International Taxation
Dr. Ambedkar Law University, Tamil Nadu, India 2001 to 2004
Bachelor of Law and Qualified to enrol into Bar of Tamilnadu
Madras University, Tamil Nadu, India 1998 to 2001
Bachelor in Bank Management
Publications and awards
Numerous articles on Data, Tax and Real Estate in Lexis Nexis.
Author Award for all-exclusive articles on Real Estate for Oman region in Lexis Nexis.
Numerous publications in Islamic Finance News.
International Corporate Procedures (Oman Section), Jordan Publishing, Bristol, UK.
Case study on Commercial Companies Law (Oman Section), Doing Business Unit, The World Bank Group, US.
Case study on Capital Market Law (Oman Section), Survey by the World Bank.
Oman tax law – Practice and Procedures, IBFD Amsterdam.
LLM at Leiden University
Advanced masters in International Tax Law from International Tax Center
May 2017 - Present
Head of Property, Tax and Corporate Finance at Al Hashmi Law