Transfer Pricing in the Middle East - Practical Challenges for UK Advisers

Introduction

UK businesses operating in the Middle East must navigate differing transfer pricing requirements across the region. Applying a global group policy requires careful consideration of local rules, commercial substance and the evidence needed to support intercompany transactions.

With a particular focus on the UAE and Saudi Arabia, this webinar will explore the practical challenges facing UK multinationals and their advisers. It will consider regional approaches to transfer pricing, common areas of dispute and the difficulties of benchmarking transactions and defending tax positions.

This webinar is aimed at accountants, corporate tax advisers and in-house tax and finance professionals advising businesses with Middle Eastern operations.

Prior knowledge of transfer pricing is assumed.

What You Will Learn

This webinar will cover the following:

• The evolving transfer pricing landscape
• An overview of the UAE, Saudi Arabia and other GCC jurisdictions
• Adoption and local interpretation of OECD principles
• Key differences from the UK transfer pricing framework
• The UAE’s transfer pricing regime
• Related-party transactions and connected persons
• Practical considerations for Free Zone structures
• Documentation requirements and demonstrating commercial substance
• Saudi Arabia and the wider GCC
• ZATCA’s approach to transfer pricing
• Navigating differing local requirements
• Maintaining consistent group policies across jurisdictions
• Intercompany transactions - common areas of challenge
• Management fees and shared services: evidencing the benefit received
• Intellectual property, financing and guarantees
• Business restructurings and aligning pricing with functions and risks
• Benchmarking and defending transfer pricing positions
• Regional comparables and limitations in available financial data
• Using international benchmarks
• Supporting positions through functional analysis and robust documentation
• Cross-border considerations for UK multinationals
• Coordinating UK and Middle Eastern transfer pricing positions
• Recognising related permanent establishment and withholding tax risks
• Double taxation, treaty considerations and conflicting tax authority positions