#Transfer pricing

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What Is Transfer Pricing & How Does It Impact My UAE-based Business?

What is Transfer Pricing?

Since the implementation of Corporate Tax in UAE, The notion of Transfer Pricing (TP) is receiving more attention in the Ministry of Finance (MoF) released Questions and Answers along with public Consultation documents.

This idea could be new for many local-owned companies, leading to numerous concerns and Transfer Pricing considerations for implementation. The topic of this article is Transfer Pricing, and its implications within The UAE will be reviewed to provide more information for businesses.

The standard definition of the term “transfer pricing” is commonly referred to as:

“The prices of goods and services sold or purchased between the entities with associated parties.”

When a related party refers to an entity or person who has a prior connection with a business by control, ownership, or family kinship (in instances of natural people).

Naturally, related-party transactions may allow entities to shift profits artificially. Therefore, this UAE corporate tax introduction strongly emphasizes transfer pricing.

The world’s tax justice network defines Transfer Pricing as “a technique used by multinational corporations to shift profits out of the countries where they operate and into tax havens.”

Both definitions explain that transfer prices are a way to make money. But it’s helpful to go back and expand the definition. It is essential to clarify that Transfer Pricing refers to the following:

A tax law to prevent abuse was enacted to implement the  “arm’s length” principle.

It is a requirement that the price of the goods and services  that the respective parties charge must be precisely the same as they     would have been being the parties involved in each transaction were     connected.

The goal of the arm’s-length rule and the Transfer Pricing (“TP”) regulations is to ensure that there isn’t any price mispricing of transfers, which can be due to fraudulent transfer Pricing methods, in which the prices of transfers are deliberately manipulated to obtain certain tax benefits which benefit several related entities.

Transfer pricing is of crucial importance to corporate taxation. Transfer prices directly impact the distribution of losses and profits for companies that are who are taxed by the corporate tax. The Transfer Pricing practices of taxpayers could have an immediate impact on the tax revenues of a nation.

When the corporate tax rates of the countries concerned differ substantially, related parties might be motivated to establish their transfer rates so that they can allocate profits to the less tax jurisdiction, thus reducing the total (group) global tax burden for corporations.

Even when a country has lower tax rates and is not governed by Transfer Pricing laws, transfer mispricing can take away significant tax revenue.

For instance:

Company A, a tax resident of Bangladesh, manufactures electronic devices and personal computers in a country taxed at a rate of 32.5 percent. It sells its items to the UAE-related tax-resident company B which pays 0 percent or 9% corporate tax on the resale of its products in third markets and UAE.

In this scenario, company A will be driven to offer the product at a price or with a lower profit percentage to Company B. In contrast, Company B will be able to resell the product with the highest possible profit margin and take the more significant part of the profits to ensure that both entities pay corporate taxes at a lower efficient tax rate.

Tax authorities in Bangladesh are likely to audit and modify the tax on corporate income paid by company A, thereby taxing a substantial portion of the profits that the UAE taxes.

Suppose company B was to pay taxes on corporate income in the UAE.

In that case, company B is likely to be keen to reduce the tax paid by the UAE to reduce and eliminate the phenomenon known as “economic double taxation” through the Transfer Pricing adjustment. That’s why countries with corporate tax systems should create transfer pricing laws and an administrative capacity to deal with the request for adjustment.

Additionally, as accounting and legal tax laws and practices vary from country to country, It is of the utmost importance to be aligned with the Transfer Pricing law to ensure that the adjustments to TP are based on the same rules and principles as the Transfer Pricing method.

Will It Impact A UAE-Based Business?

The simple answer is yes. The official MoF documents ( Press release  and Public Consultation) stipulate that UAE businesses must adhere to Transfer Pricing rules and the requirements for documentation by the Transfer Pricing Guidelines.

As part in the Corporation Tax introduction as part of the Corporate Tax introduction, the UAE will implement Transfer Pricing rules, which means that all transactions with related parties and those that involve connected individuals (“intercompany transaction”) will have to conform to the applicable TP requirements according to the principle of arm’s length that is outlined in the OECD Transfer Pricing Guidelines.

Who are the Related Parties?

By the UAE Corporate Tax Consultation Document [2(the (“Consultation Paper”), A related person is an individual or an entity with already established a connection to a business by control, ownership, or family kinship (in cases of natural people).

The document also lists these relationships in the form of related parties:

Two or more people connected with the 4th degree of kinship,     affiliation, or kinships such as marriage, birth, or adoption.

When alone or in conjunction with a partner, a person, or a legal entity, the individual directly or indirectly holds more than 50% of this legal entity.

A legal entity or two in which one legal entity or in conjunction with a related entity directly or indirectly, has more than 50% part in or controls each legal entity

More than two legal entities, if an individual taxpayer or together with a partner who directly or indirectly owns 50 percent of each.

A taxpayer, its branch, or permanent establishment

The partners in the same unincorporated partnership and

Business activities that are exempt and non-exempt of the same individual (for instance, an exempt-free zone-based business).

Who Are Connected Persons?

Consultation Paper Consultation Paper stresses that in the absence of taxation on personal income in the UAE, individuals who own tax-deductible companies would be encouraged to reduce the UAE corporate tax base through excessive payments to themselves and others who are associated with them.

So, benefits or payments offered by a company for the “Connected Persons” will be tax-deductible only if the company can prove that the benefit or payment conforms to “arm’s length” or the “arm’s length principle” and that the cost is incurred entirely and solely for the benefit of your business.

Connected Persons differ as Related Parties. A person is regarded as being ‘connected’ to a business in the scope of the UAE Corporate Tax regime it is:

A person who directly or indirectly holds an ownership control or interest in the taxable person

Director or Officer of a taxable person.

An individual who is related to the director, owner, and Officer of the tax-paying person in four degrees of affinity or kinship, such as through marriage, birth, or adoption.

If the tax-paying person is a member of an unincorporated partnership or any other partner of the same partnership and

The term “related party” refers to a Related Party of any of the above.

What Are the Compliance Obligations?

Transfer Pricing rules usually shift the burden of proof (burden of evidence) on the taxpayer. It is the responsibility of any taxpayer who has intercompany transactions that have more than a certain threshold, in the applicable tax year, to create documents for Transfer Pricing and demonstrate that the intercompany transactions were conducted at “arm’s length”.

The value of intercompany transactions has yet to be defined and is anticipated to be clarified following the implementation of UAE Corporate Tax Legislation. This Consultation Paper specifies the mandatory Transfer Pricing documentation consisting of a local file and a Master File (according to the formats and content required in OECD BEPS’s Action 13 and by the World’s Best practices).

Additionally, the arm’s-length nature of the transactions must be confirmed using one of the internationally recognized Transfer Pricing methods or another approach when the business can prove that the method specified can’t be used reasonably.

If the requirements are met, companies must complete and submit the Transfer Pricing disclosure form with details about their transactions with inter-company entities. It needs to be clarified how this Transfer Pricing disclosure form must be filed simultaneously with your tax returns (i.e., in the first (9) months from the expiration of the applicable period of tax) or with an earlier date.

[simplysolvedagency]

What Is Transfer Pricing, And How Does It Impact My UAE-based Business?

What is Transfer Pricing?

In the wake of the implementation of Corporate Tax in UAE, The idea of transfer Pricing (TP) is receiving greater attention in the Ministry of Finance (MoF) released Questions and Answers as well as the Public Consultation documents.

In the case of many locally-owned companies, this idea could be completely new, leading to numerous issues and Transfer Pricing considerations for implementation. The topic of this article is transfer Pricing, as well as its implications for UAE, which will be discussed. UAE will be reviewed to provide more information to business owners.

The most common definition of transfer pricing is commonly referred to as:

“the prices of goods and services sold or purchased between the entities with associated parties.”

A related party is an entity or person with a prior relationship with a company through control, ownership, or kinship (in instances of natural people).

Naturally, related party transactions may allow entities to manipulate profit. Therefore, a strong emphasis on transfer Pricing is evident in an introduction to the UAE corporate tax introduction. The world’s tax justice network defines Transfer Pricing as “a technique used by multinational corporations to shift profits out of the countries where they operate and into tax havens.” 

Both definitions explain that transfer prices are a way to make money. But it’s helpful to go back and expand the definition. One could include that Transfer Pricing means:

A tax law to prevent abuse was enacted to enforce the “arm’s     length” principle.

It is a requirement that the price of the goods and services     charged by the respective parties must be precisely the same as they would     be should the parties involved in this transaction have never been     connected.

The goal of the arm’s-length concept and transfer pricing (“TP”) guidelines is to ensure that there are no instances of pricing mismatch in transfers due to improper transfer Pricing methods. In which the prices of transfers are deliberately manipulated to gain certain tax advantages which benefit several related entities.

Transfer pricing is of crucial importance to corporate taxation. Transfer Pricing directly impacts the distribution of losses and profits for companies subject to corporate tax. Notably, the practices of Transfer Pricing taxpayers have an immediate impact on the tax revenues of a nation.

Suppose the tax rates for corporations of the respective countries differ significantly. In that case, the associated parties might be motivated to establish their transfer rates to allocate profits to the tax-free jurisdiction, thus reducing the total (group) global corporate tax burden.

Even when a country has lower tax rates and is not governed by Transfer Pricing laws, transfer mispricing could result in substantial tax revenue being removed.

For instance:

Company A, a tax resident of Bangladesh, manufactures electronic and personal computers in a country taxed at a rate of 32.5 percent. The company sells its manufactured items to the UAE-related tax-resident business Company B, which pays 0 percent or the corporate tax rate of 9% for the resale of its products in third markets and the UAE.

In this scenario, company A will likely be driven to sell the product for price or with a lower profit cost to company B. Company B can resell the product with the highest possible margin and take home the more significant portion of the profits, to make both companies pay corporate taxes at a lower amount.

Tax authorities in Bangladesh are likely to audit and modify the tax on corporate income paid by company A, thereby taxing a substantial portion of the profits that the UAE taxes. Suppose company B had paid taxes on corporate income in the UAE.

In that case, company B is likely to be keen to reduce the tax paid by the UAE to avoid and lessen the phenomenon known as “double economic taxation” through the transfer pricing adjustment. That’s why countries with corporate tax systems, in general, must develop transfer pricing laws and establish an administrative capacity to manage the request for adjustment.

Additionally, accounting, as well as legal and corporate tax laws and practices, vary from one country to the next and from country to country. It is essential to be aligned with the Transfer Pricing law to ensure that the appropriate TP adjustments are based on the same rules and principles as the Transfer Pricing procedure.

Will It Impact A UAE-Based Business?

The simple answer is yes. The documents published by the MoF documents ( Press release and Public Consultation) clarify that UAE companies must adhere to Transfer Pricing regulations and documentation requirements based on the Transfer Pricing Guidelines.

In the context of the Corporation Tax introduction as part of the Corporate Tax introduction, the UAE will implement Transfer Pricing rules.

That means that all transactions between related parties and persons who are connected (“intercompany transaction”) will have to comply with applicable TP requirements according to the principle of arm’s length outlined in the OECD Transfer Pricing Guidelines.

Who are the Related Parties?

As per the UAE Corporate Tax Consultation Document [22 (“Consultation Paper”), A related person is an individual an entity with an existing connection to a business by control, ownership, or family kinship (in cases of natural individuals).

The document also lists these relationships in the form of connected parties:

A minimum of two or more persons who are related with the 4th     degree of kinship or affiliation, for example, through marriage, birth, or     adoption;

When alone or in conjunction with a partner, a person, or a     legal entity, the individual directly or indirectly holds more than 50% of     this legal entity.

One or more legal bodies, where one legal entity on its own     or in conjunction with a related entity directly or indirectly, holds at     least a 50% percentage of or controls each legal entity

More than two legal entities, if the taxpayer, either alone     or in conjunction with a related person directly or indirectly, holds at     least 50% of each or is the sole owner;

A taxpayer and its branch or permanent establishment

Members of the same unincorporated partnership and

Non-exempt and exempt business activities of the same     individual (for instance, an exempt-free zone-based business).

Who Are Connected Persons?

Consultation Paper Consultation Paper stresses that in the absence of taxation on personal income in the UAE, individuals who own tax-deductible companies would be encouraged to reduce the UAE corporate tax base through excessive payments to themselves or those associated with them.

So, benefits or payments given by a company for the “Connected Persons” will be tax-deductible only if the company can show that the benefit or payment conforms to “arm’s length” or the “arm’s length principle” and the expense is entirely and solely for the benefit of your business.

Connected Persons differ as Related Parties. A person is considered as being connected to a business in the scope of the UAE Corporate Tax regime it is:

An individual who either directly or indirectly owns an     ownership control or interest in the tax-paying person.

An officer or director of a taxable person.

An individual who is related to the director, owner, or     another officer tax-paying person in the extent of the 4th degree of     family kinships such as through marriage, birth, or adoption.

If the tax-paying person is a member of an unincorporated     partnership or any other     partner of the same partnership and

A Related Party of any of the above.

What Are the Compliance Obligations?

Transfer Pricing rules usually place the onus probandi (burden of evidence) on the taxpayer. The taxpayer is responsible for intercompany transactions with an amount greater than a specific threshold in the applicable tax year to create the Transfer Pricing documents and show that the transactions between its companies were carried out at an “arm’s length.”

The value of intercompany transactions has yet to be defined and is expected to be clarified following the implementation of UAE Corporate Tax Legislation. Consultation Paper Consultation Paper does specify the mandatory Transfer Pricing documentation that will comprise a Local File along with a Master file (according to the formatting and content required in OECD BEPS Act 13 as well as following the World’s Best practices).

Additionally, the arm’s-length nature of intercompany transactions must be confirmed using any of the internationally accepted Transfer Pricing methods or another approach when the business can prove that the specified method can’t be used reasonably.

If the requirements are met, companies must complete and submit a Transfer Pricing disclosure form with information about their intercompany transactions. It is unclear how it is necessary to submit the Transfer Pricing disclosure form will need to be filed simultaneously with when filing the tax return (i.e., at least 9 months from the date of expiration of the relevant period of tax) or by an earlier date.

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UAE Corporate Tax Transfer Pricing Guide

Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses (“Corporate Tax Law”) was issued on 3 October 2022 and published in Issue #737 of the Official Gazette of the United Arab Emirates on 10 October 2022. This law establishes the legal framework for imposing a federal tax on corporate and business profits in the UAE. Its provisions apply to tax periods beginning on or after 1 June 2023.

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What is Transfer Pricing?

Transfer pricing refers to the pricing of goods, services, or intangible assets within a multinational organization. It is a critical aspect of international taxation, as it ensures that transactions between related entities are conducted at arm's length, reflecting fair market value. Accurate transfer pricing is essential to prevent tax avoidance, ensure compliance with regulations, and reduce the risk of disputes with tax authorities.

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When it comes to TRANSFER PRICING, CA Harshal Sevak is well-versed in ensuring fair and compliant transactions between related parties. His in-depth understanding of this complex area of #taxation allows him to assist you in achieving optimal results and mitigating risks.

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Understanding the Importance of FAR Analysis in Transfer Pricing Compliance

Imagine, for a moment, you're at the helm of a multinational enterprise, steering the ship through the tumultuous waters of global business.

As a business leader, you must ensure that your enterprise navigates these waters successfully and complies with the myriad of international tax regulations. One such critical regulation is Transfer Pricing, a concept that often proves to be as complex as it is crucial.

This article simplifies this concept and highlights the importance of Function, Asset, and Risk (FAR) Analysis in maintaining Transfer Pricing compliance, particularly within the Indian context.

Now, let's delve into the world of Transfer Pricing and FAR Analysis, where understanding and adhering to these rules could mean the difference between smooth sailing and rough seas.

Neglecting a robust FAR Analysis could lead to severe consequences, such as hefty penalties and a tarnished reputation.

Understanding Transfer Pricing

Transfer pricing refers to the pricing of transactions between associated enterprises. It is a regular part of the operations of a multinational company but needs careful attention due to varying tax laws across countries.

The arm's length principle, which suggests that transactions between related parties should be conducted as if they were unrelated, forms the basis of most countries' transfer pricing rules, including India's.

The Concept of FAR Analysis

At the heart of transfer pricing is the concept of FAR analysis - Functions performed, Assets used, and Risks assumed.

It is a vital tool used in transfer pricing studies to compare the functions performed, assets employed, and risks the tested party assumes with those of independent enterprises engaging in comparable uncontrolled transactions.

Detailed Explanation of FAR Analysis

In simpler terms, the functions refer to each entity's activities in the transaction, the assets to the resources they employ, and the risks to the uncertainties they assume. Understanding the FAR profile helps identify comparable uncontrolled transactions, which are then used to determine the arm's length price.

Rule 10B and the Necessity of FAR Analysis

Rule 10B of the Income Tax Rules underscores the importance of FAR Analysis in determining whether a transaction is at arm's length. This rule mandates the use of FAR Analysis in the process of identifying comparable uncontrolled transactions.

Case Studies Illustrating the Importance of FAR Analysis

Understanding the theoretical concept of FAR analysis is one thing, but witnessing its application in real-world scenarios truly underscores its importance.

The Supreme Court Case of Morgan Stanley and Company Inc.

Let's consider the Supreme Court case of Morgan Stanley and Company Inc., a U.S. investment bank, which entered into an agreement with its group company in India for certain support services.

The question was whether Morgan Stanley had a permanent establishment in India, and if so, what income was attributable to it.

The Supreme Court held that the employees sent on deputation constituted a service PE of the assessee, and the income of the non-resident assessee was taxable in India to the extent of income attributable to the activities carried on by the non-resident through its permanent establishment in India.

This case illustrates the importance of a detailed FAR analysis in determining an international transaction's arm's length price​.

The Case of Hoganas India (P.) Ltd. V. Dy. CIT and Wrigley India (P.) Ltd. V. Addl. CIT

Further, the cases of Hoganas India and Wrigley India showcase the application of FAR Analysis in real-life scenarios. These cases underscore how an in-depth FAR Analysis can help businesses avoid disputes and achieve compliance with transfer pricing regulations.

A thorough FAR analysis played a crucial role in determining the correct transfer pricing in these cases.

Key Takeaways from FAR Analysis

Transitioning from the intricacies of Transfer Pricing and FAR Analysis, here are the key takeaways from the article:

* Transfer pricing refers to pricing transactions between related business entities, a critical aspect of international tax compliance.

* Function, Asset, and Risk (FAR) Analysis is central to transfer pricing.

* FAR Analysis is not merely a compliance requirement; it's a tool that helps businesses navigate the complex waters of international transactions, ensuring fair pricing and avoiding penalties.

* FAR Analysis is mandated by Rule 10B of the Income Tax Rules to ensure transactions are at arm's length.

* FAR Analysis should be integrated into the transfer pricing strategy of multinational businesses operating in India.

Furthermore, a robust FAR Analysis maintains the company's reputation and promotes good corporate governance.

Conclusion:

FAR analysis is not just a compliance requirement. It is a powerful tool that can help businesses to set prices that reflect the economic reality of their transactions, thereby reducing the risk of double taxation and potential penalties.

It helps companies to identify the most suitable comparables for their transactions, allowing them to benchmark their prices against the market and ensuring that they comply with the arm's length principle.

As such, it should be seen as an integral part of the transfer pricing strategy of any multinational business operating in India.

Source: https://www.manishanilgupta.com/blog-details/understanding-the-importance-of-far-analysis-in-transfer-pricing-compliance

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