Mr. Avinash is a Mauritian who own consultancy firms in Mauritius and Dubai. His firm in Mauritius has provided consultancy services for the sale of a 5-Star Hotel in Seychelle for Euro 100 million. The company is entitled to earn 2% for the selling price as fees. Mr Avinash is considering to invoice the consultancy fee from the Dubai entity. You are requested to critically analyse the proposed action for Mr Avinash from both a tax perspective and the legal perspective.