UAE – TP Disclosure Form

UAE TransferPricing (TP) disclosure form is now enabled in the EmaraTax Portal. The taxpayers while filling out the corporate tax return need to fill in the details on the TP discourse form.

The form provides the list of information which needs to be captured – related party transaction, connected person, adjustment to gains and losses relating to opening balances w.r.t RPT.

VSTN’s alert captures in detail the contents of the form and also provides key aspects and takeaways for business in relation to:

1. No threshold / de-minimis limit w.r.t. transactions
2. Option for entities going in for smallbusiness relief (SBR)
3. As other method has not been listed in the drop down for the most appropriate method (MAM)- what approach can one adopt
4. Payment to connected person – No option provided for disclosure of the MAM
5. Position for entities forming part of Taxgroup
6. Suo motto adjustment in the return – is the adjustment required to the median or lower quartile
7. Instances where combination of methods are considered, as permitted by UAE TP regulations
8. Maintenance of localfile / Masterfile as mentioned in UAE CT Law Vs actual filing of document – viewed as a proof for contemporaneous documentation
9. Other transactions – receivables, free of cost – positions one can adopt

Taxpayers and stakeholders, at large, are awaiting the FTA to issue guidance on the TP Disclosure form for enabling taxpayers to file the appropriate information as well be “Tax-ready” w.r.t. TP compliances expected from a UAE perspective.

VSTN can support UAE business on the transfer pricing requirements and can help to guide taxpayers through the required compliances and also help to streamline the transactions to ensure effective implementation of the TP policies.

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