Nimrod Thien

Nimrod is an Associate in the Tax practice in the Dubai office, specialising in corporate and international tax, including Pillar Two.

He has over six years’ experience advising on tax structuring, M&A transactions, and compliance matters across the UAE and New Zealand. Nimrod works with a range of clients, including multinational groups, financial institutions and sovereign entities, providing practical and commercially focused tax advice across complex, cross-border matters.

Nimrod has particular experience in international tax structuring and the application of Pillar Two rules, advising clients on the tax implications of multi-jurisdictional operations, reorganisations and investments. His background in tax compliance and experience interacting with tax authorities enables him to deliver solutions that are both technically robust and practically implementable.

Prior to joining Hadef & Partners, Nimrod worked at leading international professional services firms in the UAE and New Zealand.

Nimrod is admitted to practice in the High Court of New Zealand and is fluent in English, Mandarin Chinese and Malay.

• Prepared a Pillar Two tax transaction guide for a UAE Sovereign Wealth Fund in respect of future acquisitions / joint ventures.
• Advised a UAE-listed airline group on its international tax and Pillar Two presence in relation to double tax treaties, air services agreements, and the ‘subject to tax rule’.
• Advised on the corporate tax and Pillar Two tax implications of a redomiciliation of a global financial services group into the UAE, and subsequent structuring of UAE free zone entities.
• Advised various foreign multinational groups on New Zealand permanent establishment implications resulting from their presence and operations in New Zealand.
• Advised overseas trusts and foundations on the structuring of their New Zealand investments.
• Advised on the operation of the NZ energy and financial services tax regime, and more broadly on debt / equity financing, profit repatriation / exit considerations, fund set-up and structuring, as well as tax implications of adopting different entity and contract structures.
• Assisted with the review of various tax sales and purchase agreements and entity establishment documents across several public transactions in New Zealand.
• Assisted with due diligence reviews of various tax documents (including tax returns, correspondence with tax authorities, and internal tax governance policies) across several public transactions in New Zealand.