PKF UAE Transfer Pricing (TP) Offerings

As a part of UAE corporate tax regime, it is also proposed to introduce Transfer Pricing (‘TP’) provisions, to regulate the transactions between related parties, and requiring the taxpayers to maintain necessary documentation to justify pricing of their related party transactions, so that such related party transactions do not become a tool for erosion of tax base.

TP principles are well recognized globally and multinational enterprises having cross border transactions with related parties need to comply with TP provisions in each jurisdiction, having regard to local TP laws and global TP policies.

  1. Trainings: Conducting informative sessions for clients/ taxpayers on the proposed transfer pricing regime and how to be prepared for the same.
  2. Initial Impact Assessment & Advisory:
    • Review of intra-group transactions to ascertain applicability of UAE TP provisions
    • Identification of related party/connected person as per the proposed UAE CT regulations.
    • Review of the intercompany agreements from TP perspective and advising on the same for complying with UAE TP provisions.
    • Advice on developing and implementing policies and procedures for monitoring intercompany transactions and transfer pricing.
    • Advising on future ready transfer pricing strategies to optimize cash flows and taxes and developing transfer pricing policies.
    • Need based on-call advisory services based on transfer pricing of cross border transactions/transactions with related party/ connected persons.
  3. TP Compliance & Implementation support:
    • Preparation and filing of Transfer Pricing Disclosure Forms, documentation, as may be applicable.
    • Assistance in the preparation of Country-by-Country Report, master file, local file, etc., as may be required.
    • Conducting functional interviews and documenting the functions performed, assets employed, and risk assumed for the intra-group transactions.
    • Preparation of benchmarking studies and other required TP documentation, as may be prescribed by law.
  4. Representation services:
    • Advising on whether any ‘Clarification’ is required from the UAE Federal Tax Authority (FTA) and assistance in obtaining the same.
    • Assistance in preparation and filing of written submissions against notices received from FTA.
    • Assistance in representation before FTA.

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