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The new Transfer Pricing regime in the United Arab Emirates

On 31 January 2022, the Ministry of Finance (MoF) of the United Arab Emirates (UAE) announced that the UAE will introduce a Federal Corporate Tax (CT) on business profits that will be effective for financial years starting on or after 1 June 2023. On 28 April 2022, a Public Consultation Document (PCD) was published with more detailed information on the proposed UAE CT regime with the intention of seeking views from interested parties and stakeholders before implementation.  

On 9 December 2022, the UAE released the Federal Decree-Law No. 47 of 2022, issued on 3 October 2022, on the Taxation of Corporations and Businesses (CT Law). In addition, the MoF released 158 Frequently Asked Questions (FAQs) to provide guidance on the UAE CT regime. The CT Law will be administered by the Federal Tax Authority (FTA). 

In this publication we provide an overview of the CT Law in the context of the UAE Transfer Pricing (TP) rules, the potential impact, and how UAE businesses can address their TP framework going forward. 

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