The United Arab Emirates (UAE) Ministry of Finance (MoF) has recently issued Ministerial Decision No. 97 of 2023, accompanied by a comprehensive 107-page Explanatory Guide on Taxation of Corporations (the CT Law), scheduled to take effect from 1 June 2023.
This guidance provides additional information on the UAE Transfer Pricing (TP) regime, aligning it with the Organisation for Economic Cooperation and Development (OECD) TP Guidelines. The implications of these changes, particularly on intra-group transactions, are expected to be far-reaching.
Following the release of this decision, our Transfer Pricing team held a 60-minute webinar on Tuesday, 23 May 2023 at 11:00am (UAE time). During this session our experts discussed the latest TP developments and their impact on multinational businesses operating in the UAE.
Speakers
Mohamed Serokh
As the Growth Leader for our Tax Services practice, Mohamed is a key member of our leadership team, responsible for spearheading our growth strategy in the Middle East. This includes strategy to identify and pursue new market opportunities, creating and implementing business development initiatives, reflecting the latest industry trends, and collaborating with the wider tax leadership team to achieve revenue growth targets. As Growth tax Leader, Mohamed is also responsible for leading strategy on accelerating our growth platform, proposal management, driving and promoting client excellence, and promoting our capabilities and industry leadership through marketing and eminence efforts. In addition to spearheading our growth initiatives, Mohamed leads our award-winning and market-leading regional Transfer Pricing team. The team’s transfer pricing services span three key areas: consulting, controversy and compliance, and supporting clients in all industries and sectors. As a Transfer Pricing specialist and a former regulator, Mohamed has more than 25 years’ experience in transfer pricing, international tax, strategic, economic and business consulting across a number of industry segments. These include the automotive, construction and materials, energy, financial services, pharmaceutical, telecommunications and media, technology and travel and leisure sectors. His experience includes leading and managing global documentation and planning studies, as well as drafting Advanced Pricing Agreements (APAs) for submission to tax authorities in jurisdictions worldwide. Mohamed presents widely on transfer pricing and tax issues at seminars across the world and has been extensively published in the area of transfer pricing and tax on different platforms. In 2020, Mohamed was awarded the International Tax Review (ITR) Editor’s Choice Award for progressive work throughout the Middle East in Transfer Pricing and was nominated for the EMEA Transfer Pricing Practice Leader of the Year award. Mohamed was awarded an MBA (with distinction) from Warwick Business School, where he won an award for the overall best MBA degree of the year. Mohamed also holds MSc Economics (with distinction) and BSC Economics (first class) degrees from the University of London.
Rabia Gandapur
Rabia is a Partner in the Transfer Pricing team covering the Middle East. She has been based in the region for the last 3 years, having moved here after 10 years in the UK with a Big 4 firm. Rabia is a UK Chartered Tax Advisor and financial economist. Rabia has extensive experience advising multinationals on complex TP planning, design and documentation projects as well as supporting clients on their operational, governance and implementation strategies. She has supported various multinationals, SWFs and family groups in respect of the transfer pricing and Country-by-Country Reporting requirements. Rabia has advised on multiple Advance Pricing Agreements (APAs) and Mutual Agreement Procedures (MAP) in the UK and supports clients in the Middle East with TP audits and controversy.
