UAE: Transfer pricing guide issued
Insights and illustrative examples on various aspects of the UAE transfer pricing regime
Insights and illustrative examples on various aspects of the UAE transfer pricing regime
The UAE tax authority on 23 October 2023 issued an extensive transfer pricing guide—offering insights and illustrative examples on various aspects of the UAE transfer pricing regime including:
- 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
- Transfer Pricing audits and risk assessments
The guide takes into consideration the guidance provided by the 2022 Organization of Economic Cooperation and Development (OECD) Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.
KPMG observation
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 UAE tax authority will consider the regime.
In addition, to the extent any aspect/issue of the transfer pricing regime is not covered in the guide, UAE taxpayers may want to refer to the OECD transfer pricing guidelines.
Read an October 2023 report [PDF 1 MB] prepared by the KPMG member firm in the United Arab Emirates
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