8 Feb.

The new Transfer Pricing regime in the United Arab Emirates

Webinar recording

Event language: English

Held: 8 February 2023 | Duration: 1 hour

The Ministry of Finance (MoF) of the United Arab Emirates (UAE) announced that the UAE will be implementing a Federal Corporate Tax (CT) for business profits that will be effective for financial years starting on or after 1 June 2023.

The Federal Decree-Law No. 47 of 2022 was issued on October 3, 2022, on the Taxation of Corporations and Businesses, Corporate Tax Law (CT Law) to enact a new CT regime in the UAE.

In addition, the MoF released 158 Frequently Asked Questions (FAQs) to provide guidance on the UAE CT regime. The CT Law also includes a comprehensive Transfer Pricing (TP) regime in line with the Organisation of Economic Cooperation and Development (OECD) TP Guidelines, which could have a far-reaching impact, especially on intra-group transactions.

Our TP experts conducted a webinar on Wednesday, February 8, to elaborate on the TP rules in the UAE and their impact on multinational businesses operating within the UAE. The session covered a number of topics with reference to CT, including:

  • The arm’s length principle;
  • Related parties, control, and payments to connected persons;
  • TP adjustments,
  • Tax groups and groups relief;
  • Next steps and action items.


Mohamed Serokh

Mohamed Serokh

Middle East Growth Tax Leader | Middle East Transfer Pricing Leader

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 Gandapur

Partner | UAE Transfer Pricing Lead

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.

Recommended for you

Wednesday, 8 Feb 2023
Share Share event on social