Programme Format: 8 Days | 4 Modules | 24 Learning Hours
An end-to-end programme from the arm’s length principle to audit defence, aligned with the UAE Corporate Tax Law and the Federal Tax Authority’s transfer pricing guidance.
Days 1–2 Module 1 · 6 Learning Hours
MODULE 1 · DAY 1 · 3 Hours
Foundations and Scope
Foundations, Scope and the Arm’s Length Framework
- Why transfer pricing matters under the UAE Corporate Tax regime; OECD and UN foundations
- The arm’s length principle, Market Value and deemed distributions
- Scope: domestic and cross-border dealings, including Free Zone, Exempt and Small Business Relief counterparties
- Related Parties and Connected Persons: ownership, control and significant influence; PEs, partnerships and trusts; payments to owners, directors and officers
- Practical: Mapping the Controlled Transactions of a UAE group
MODULE 1 · DAY 2 · 3 Hours
Accurate Delineation and Functional Analysis
Understanding the Transaction and Selecting the Tested Party
- Contractual terms versus actual conduct of the parties
- Functions, assets and risks: control over risk and financial capacity
- Comparability factors, business strategies, group synergies and location-specific advantages
- Selecting the tested party
- Case: Delineating a distribution and service arrangement
Days 3–4 Module 2 · 6 Learning Hours
MODULE 2 · DAY 3 · 3 Hours
Transfer Pricing Methods and Benchmarking
Methods, Comparables and the Arm’s Length Range
- CUP, Resale Price, Cost Plus, Transactional Net Margin and Profit Split methods
- Choosing the most appropriate method; combining methods
- Internal and external comparables; local versus regional data
- Comparability adjustments, the arm’s length range and multi-year analysis
- Practical: Benchmarking search strategy, screening and documentation
MODULE 2 · DAY 4 · 3 Hours
Financial Transactions
Loans, Guarantees and Treasury Arrangements
- Treasury functions, intra-group loans, credit ratings and implicit group support
- Cash pooling, hedging, financial guarantees and captive insurance
- Overdue intercompany balances and their recharacterisation as financing
- Interaction with the interest deduction limitation rules
- Case: Pricing an intra-group loan and guarantee
Days 5–6 Module 3 · 6 Learning Hours
MODULE 3 · DAY 5 · 3 Hours
Services, Intangibles and Cost Contribution Arrangements
Benefit Tests, DEMPE and Intra-Group Arrangements
- The benefit test; shareholder, duplicative and low value-adding services
- Cost bases, allocation keys and mark-ups
- Intangibles: identification, DEMPE functions, legal versus economic ownership and valuation techniques
- Cost contribution arrangements: contributions, balancing payments, entry and exit
- Case: Defending a management fee and a royalty
MODULE 3 · DAY 6 · 3 Hours
Business Restructurings and Permanent Establishments
Restructuring, Compensation and Profit Attribution
- Conversions to limited-risk models, IP centralisation and concentration of functions
- Compensation for transfers of functions, assets, risks and going concerns
- Attribution of profits to permanent establishments under the separate entity approach
- Interplay with Qualifying Group and Business Restructuring reliefs
- Case: Restructuring a UAE distributor into a limited-risk model
Days 7–8 Module 4 · 6 Learning Hours
MODULE 4 · DAY 7 · 3 Hours
Documentation and Compliance
Disclosures, Master File, Local File and CbCR
- Contemporaneous documentation and annual review of the transfer pricing policy
- Disclosure with the Tax Return: Related Party and Connected Persons schedules and thresholds
- Master File and Local File: who must prepare, contents and exceptions
- Country-by-Country Reporting and Tax Group considerations
- Practical: Building a Local File from information request to final report
MODULE 4 · DAY 8 · 3 Hours
Audit, Dispute Resolution and Capstone
Audit Defence and an End-to-End Transfer Pricing Policy
- Burden of proof and responding to FTA information requests
- Authority-initiated and taxpayer-initiated adjustments; corresponding adjustments
- Non-recognition, anti-abuse interaction, Mutual Agreement Procedure and advance pricing agreements
- Capstone: Transfer pricing policy for a UAE-headquartered group and a Free Zone structure; Pillar Two and QDMTT interplay
The Learning Journey
1. Build the FoundationUnderstand scope, related parties and the arm’s length framework
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2. Price the TransactionApply methods, benchmarking and financial transaction principles
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3. Address ComplexityManage services, intangibles, restructurings and PEs
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4. Defend the PositionDocument, disclose and prepare for an FTA review
Who Should AttendTax, finance and legal professionals, advisors and in-house teams of UAE groups and multinationals
Structure
- 4 modules
- 8 sessions
- 3 hours per session
- 24 hours in total
FormatInstructor-led; every session combines instruction with a worked case or practical exercise
Expert-Led
Instruction
Practical
& Applied
Worked Cases
& Exercises
UAE CT & FTA
Aligned
Certificate
of Completion
From the Arm’s Length Principle to Audit Defence.
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