Transfer Pricing Documentation Under Corporate Tax
Transfer pricing is a set of rules and methods for pricing transactions between related parties, such as companies that are part of the same multinational enterprise (MNE). The goal of transfer pricing is to ensure that these transactions are priced on an arm’s length basis, i.e., as if they were conducted between independent parties. The UAE introduced transfer pricing rules in 2023 as part of its new corporate tax regime. The transfer pricing rules in the UAE are broadly aligned with the OECD Transfer Pricing Guidelines. This means that UAE businesses can use the same transfer pricing methods and documentation requirements as businesses in other countries that follow the OECD Guidelines. Transfer pricing is an important compliance issue for UAE businesses. If a business is found to have engaged in transfer pricing arrangements that are not on an arm’s length basis, it could face financial penalties from the tax authorities. The Importance of Transfer Pricing Documentation If you are a business in the UAE, you should seek professional advice on transfer pricing to ensure that you are complying with the rules and avoiding penalties. Here are some of the key things to know about transfer pricing in the UAE: Understanding Transfer Pricing Documentation Transfer pricing documentation is a set of documents that businesses must keep to support their transfer pricing policies. This documentation helps to ensure that the tax authorities are satisfied that the prices charged in transactions between related parties are on an arm’s length basis. The transfer pricing documentation requirements in the UAE are set out in Ministerial Decision No. 97 of 2023 on Maintaining Transfer Pricing Documentation. The decision applies to all businesses in the UAE, regardless of their size or industry. The required documentation includes: The tax authorities may request additional documentation from businesses, depending on the specific circumstances. Businesses should keep all relevant documentation in a safe and secure place for at least five years. Requisites and Thresholds for Keeping a Master File and Local File The two main types of transfer pricing documentation are the Master File and the Local File. Both files are to be maintained by entities that meet any of the below conditions: The file must be maintained by all taxpayers who are: The Local File Transfer pricing documentation is an important requirement under corporate tax UAE to ensure multinational groups properly value cross-border transactions between related parties. Without proper documentation, the UAE tax authority may adjust transfer prices, resulting in higher taxes. AB CAPITAL Can Assist Companies in Several Ways: In essence, thorough and well-supported transfer pricing documentation serves as a crucial tool to reduce tax liabilities and mitigate the risk of tax audits for multinational corporations operating in the UAE. The consultants at AB Capital Services boast extensive expertise in crafting transfer pricing studies tailored for UAE-based clients, aiming to aid your company in achieving compliance and effectively managing transfer pricing challenges. Our services not only encompass top-tier tax consulting but also aim to support you in maintaining an efficient tax framework. Feel free to reach out to us today to discover further insights into how our expertise can assist you in addressing transfer pricing documentation needs and navigating other vital tax-related concerns.
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