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UAE Corporate Tax: Revised Transfer Pricing Regulations

27/04/2024
UAE Corporate Tax: Revised Transfer Pricing Regulations

Dubai: The Ministry of Finance issues updated regulations on Transfer Pricing under the UAE Corporate Tax. The Ministerial Decision No (97) of 2023 addresses the revised requirements for maintaining transfer pricing documentation in the context of Corporate Tax in Dubai.

The decision specifically outlines the conditions where taxpayers are obligated to maintain transfer pricing documentation. This includes the necessity of a master file and a local file if the taxpayers generate revenues of at least Dh200 million in a relevant tax period or if they are affiliated with a multinational group that generated at least Dh3.15 billion in total revenue during the relevant tax period.

The implementation of Federal Decree Law No (47) of 2023 safeguards the pricing integrity of transactions conducted among related parties and connected persons, including companies operating within the same multinational enterprise. These regulations aim to ensure that they remain free from any influence arising from their interconnected relationships.

Younis Haji Al Khouri, Undersecretary of the Ministry of Finance, stated that “Transfer pricing documentation requirements must demonstrate the arm's length basis for pricing transactions with related parties and connected individuals using standardized files.

The Decision also specifies the threshold for preparing master and local files as well as certain transactions that are excluded from disclosure to minimize taxpayer compliance burdens."

The compliance burdens for SMEs will be eased by the transfer pricing documentation requirements.

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