Bank Advisory

TRANSFER PRICING

Transfer pricing has gained significant importance due to globalization and the ever-increasing cross-border trade by businesses. In line with the Organisation for Economic Co-operation and Development (OECD) regulations, Ministry of Finance (MoF) has issued transfer pricing rules outlining how to regulate transactions and document the pricing of transactions between related parties or connected persons. The transacting group entities can use their transactions and arrangements to shift earnings from group entities in higher tax countries to group entities in lower tax jurisdictions, and from high-tax entities to low tax entities, resulting in an overall reduced tax burden for the group. 

To avoid any pricing discrepancies, Federal Tax Authority (FTA) may examine the arrangements between the related parties or payments made to the connected persons to determine if the given arrangements / payments were priced at market value.  If a transaction is not found to be at arm's length with market value, FTA may perform a transfer pricing adjustment.

Some cases when transfer pricing becomes applicable are:

 

  • If one entity undertakes a transaction / enters into an arrangement with another group entity, within or outside UAE; and the two group entities qualify as related parties.
  • If one entity makes any payment or provides any benefit to the connected person.

Impact Assessment

Analyzing the Ripple Effect: A Comprehensive Impact Assessment for Informed Decision-Making.

Quantitative & Qualitative Assessment ·

Conducting a dual approach, our assessment combines quantitative metrics and qualitative insights

Model Structuring

"Optimizing performance and clarity, our model structuring involves meticulous organization

Risk Assessment

Thoroughly evaluating potential challenges and uncertainties, our risk assessment identifies, analyzes, and mitigates risks

Tax Grouping Considerations

"Navigating intricate tax landscapes, our consideration of tax grouping involves strategic categorization to optimize fiscal efficiency

Tax Grouping Considerations

Delving into tax grouping nuances, we meticulously explore considerations to optimize financial strategies

TP Policy

Transfer Pricing Policy serves as a vital framework, guiding multinational entities in determining fair prices for intra-group transactions. It establishes arm's length principles, fostering transparency and compliance with tax regulations across jurisdictions.

Policy Implementation

TP Compliance Regulation

Benchmarking Analysis

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