Transfer Pricing

A global bird’s eye view on your business risks and functions

Organisations that operate across international borders face increasingly complex regulatory and tax issues in the different jurisdictions where they operate. Transfer pricing is a major tax priority for many privately owned and large businesses. We offer a range of support for transfer pricing management so you can ensure compliance with the different tax regulations.

The UAE Corporate Tax legislation has introduced a comprehensive Transfer Pricing regime in line with the OECD TP Guidelines for years beginning on or after 1st June 2023. Discussions around Intra-group transactions or arrangements and transactions with connected persons are key focus areas for both GCC businesses and MNCs having UAE presence.

Our team has substantial experience in transfer pricing projects across various tax jurisdictions including GCC and has experience working closely with tax authorities. The team is rightly placed in devising and implementing robust and pragmatic arm’s length policies for intra- group arrangements and providing transfer pricing advisory and compliance support.Our approach

We tailor our specialist services to support your unique needs. Our specialists have a proven track record of working with businesses across a range of sectors. They specialise in the R&D space, and HMRC.

We look at the bigger and broader picture of your business. R&D tax relief is only one aspect. We understand the importance of interconnectivity in a business and that you prefer to work with people who can help you be efficient and grow dynamically.

Our approach

Through our global network, we are able to provide vital information and support to our clients, tracking developments on legislation. Our transfer pricing experts who have in-depth industry knowledge both locally and internationally.

Our service begins with a diagnostic risk assessment that seeks to highlight areas for savings, as well as compliance and potential exposure. We then work closely with you to make sure you can meet your documentation obligations and optimise your overall tax positions.

Our services

Eton Rose Consulting can offer specialist transfer pricing services to our clients which includes:

• Strategic advice on all aspects of transfer pricing
• Master file, local file and country by country reporting
• Tax audits, mutual agreement procedures
• Value chain analysis and transformation
• Economic analyses, including commercial benchmarks, loan benchmarks, and license benchmarks
• Cash pools and other integrated group-wide financing systems
• Transfer of functions, valuation of transfer packages, exit taxation
• Valuation of intangibles