I've heard some companies shift profits elsewhere to cut their tax bill — is that possible under UAE rules?
I've heard some companies shift profits elsewhere to cut their tax bill — is that possible under UAE rules?
The first layer is transfer pricing under Article 34: any transaction between related parties — whether within the UAE or cross-border — must be priced as independent parties would price it under comparable conditions. Businesses with revenue above AED 200 million (or a consolidated group above AED 3.15 billion) must maintain a master file and local file documenting their pricing methodology, and above AED 3.15 billion a Country-by-Country Report is also required. These thresholds aren't a formality — the FTA uses them to flag margin distortions between related entities.
The second layer is the General Anti-Abuse Rule under Article 50, which applies even when pricing itself is entirely correct: if an arrangement has no genuine commercial purpose beyond obtaining a tax advantage inconsistent with legislative intent, the authority can disregard that step or recharacterize the transaction entirely — and this applies retroactively from 25 October 2022. The third layer is the requirement of genuine economic substance, particularly for entities benefiting from the 0% rate as qualifying free zone persons: real management, decisions actually taken within the country, and genuine staff and assets, not just a license. All three layers work together to close off any attempt at artificial profit shifting. RASEEKH builds company structures to withstand all three tests together, not just one of them.