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Transfer Pricing
In collaboration with our associated firm in the Netherlands, we offer reliable and cost-efficient Transfer Pricing services, including TP Study and Functional Analysis, TP benchmarking, TP Disclosure, and TP Documentation, encompassing Master File, Local File, and Country-by-Country Reporting in XML format. As part of the Trasnfer Pricing Scope, we provide,
1. High level TP assessment through a detailed questionnaire and interviews with key personnel to understand the detailed functional profile in relation to the assessed transactions.
2. We provide the TP assessment report in a PowerPoint presentation with key findings and recommendations relating to transfer pricing. The outcome of this analysis determines the scope of work necessary to become TP compliant.
3. Function, Asset, and Risk Analysis: Based on the outcomes of step one, more detailed analysis will be undertaken on the selected entities/activities to identify transactions for benchmarking, TP policies and pricing.
Frequently Asked Questions
Yes, group companies can file on consolidated tax return.
Yes, it will be and additionally eliminating the Transfer Pricing requirements.
Transfer pricing refers to the pricing of transactions between related entities, particularly those involving the transfer of goods, services, or intellectual property across international borders.
Yes, the UAE has Transfer Pricing regulations applicable on,
1. Taxable Persons who is a Constituent Company of a Multinational Enterprises Group as defined in the Cabinet Decision No.44 of 2020 and the total Consolidated Group Revenue exceeded AED 3.15 billion.
2. Taxable Persons whose Revenue is over AED 200 million in a taxable year.
The Federal Tax Authority (FTA) in the UAE oversees transfer pricing regulations and compliance. Businesses must follow the guidelines provided by the FTA.
The arm's length principle requires related entities in the UAE to set prices for transactions as if they were dealing with unrelated parties, ensuring fairness and preventing profit shifting.
Transactions involving the transfer of goods, services, or intellectual property between related parties, especially those with cross-border implications, are subject to transfer pricing regulations.
Businesses in the UAE need to maintain comprehensive documentation, including TP Benchmarking Study and Analysis, FAR, Risk Analysis, Identifying Transactions that need benchmarking, supporting documentation for determining TP Pricing, to demonstrate compliance with the arm's length principle. The taxable person will be required to file TP documents including the Master file and Local Files within the 30 days following the request by the Authority.
Master File is a master document which provides an overview of the business and include information such as corporate structure of the group.
Local files are documents typically contain more detailed information on the Related Party Transactions of the Associated Enterprises.
Non-compliance with transfer pricing regulations in the UAE may result in penalties. It's crucial for businesses to ensure adherence to avoid financial implications.
By appointing the most experienced and trustable TP advisors who have years of experience and have additional experience working with the Tax Authorities. They know what is best for their clients and can prepare an accurate documentation.