In the attached publication, we provide an overview of the UAE TP Guide in the context of the UAE Transfer Pricing rules and key takeaways for UAE businesses to address their Transfer Pricing framework going forward.Ĭlick here to read the full Guide and here for KPMG Tax Flash on the Ministerial Decision No. Although the Guide is not a legally binding document, it will be the primary source of guidance for Transfer Pricing related matters going forward and can be used as an indication of how the FTA will consider the regime. OECD updates transfer pricing country profiles to include new fields on financial transactions and permanent establishments. The OECD Transfer Pricing Guidelines provide guidance on the application of the arm’s length principle, which is the international consensus on the valuation of cross-border transactions between associated enterprises. To the extent any aspect/issue is not covered, UAE taxpayers are encouraged to refer to the OECD TP Guidelines. OECD releases new transfer pricing profiles for 21 countries. For taxpayers, it is essential to limit the risks of economic double taxation. The UAE TP Guide takes into consideration the guidance provided by the 2022 Organization of Economic Cooperation and Development Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (‘OECD TP Guidelines’).Īs such, UAE taxpayers should rely primarily on the CT Law, Ministerial Decision No. The UAE TP Guide offers insights and illustrative examples on various aspects of the UAE Transfer Pricing (‘TP’) regime, such as the application of the arm’s length principle, Transfer Pricing Documentation, considerations for specific transactions like financial transactions, intra-group services, intangibles and cost contribution arrangements, as well as Transfer Pricing audits and risk assessments. 140-page Transfer Pricing Guide (the ‘UAE TP Guide’). In the most recent publication dated 23 October 2023, the FTA issued an extensive c. The guidance now has been incorporated in the 2022 edition of the OECD TP Guidelines, mainly in new Chapter X. The UAE Federal Tax Authority ('FTA’) has been gradually introducing guides and publications to the various aspects covered in the UAE Corporate Tax Law (‘CT Law’). The 2020 report on the transfer pricing guidance on financial transactions 3 contained follow up guidance in relation to BEPS Action 4 (Limiting Base Erosion Involving Interest Deductions and Other Financial Payments) and Actions 8-10.
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