Transfer Pricing (Corporate Tax in UAE)

Understanding the KEY terms of Transfer Pricing Related Party (Article 35) Relationships that extend to the fourth degree of kinship or connection, including those formed through adoption or guardianship. Individuals or legal entities, whether acting alone or with associated parties, that hold a 50% or greater ownership stake in another legal entity, either directly or indirectly. Individuals or legal entities, acting alone or with associated parties, that exercise control over legal entities, either directly or indirectly. Two or more organizations that are under the shared control of an individual (either alone or with associated parties). An individual and their Permanent Establishment or Foreign Permanent Establishment. Partners involved in the same unincorporated partnerships. An individual who serves as a trustee, founder, settlor, or beneficiary of a trust or foundation, along with their related parties. Control (Article 35) Ability to determine the composition of 50% or more of the Board of Directors Ability to determine, or exercise significant influence over, the conduct of the business and affairs of another person Ability to receive 50% or more of the profits of another person Ability to exercise 50% or more of the voting rights Connected Person (Article 36) Owner of taxable person Related party of any of the above Director or officer of taxable person A payment or benefit provided by a Taxable Person to its Connected Person shall be deductible only if and to the extent the payment or benefit corresponds with the Market Value of the service, benefit or otherwise provided by the Connected Person and is incurred wholly and exclusively for the purposes of the Taxable Person’s Business