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BSAB LLCDubai
Insights

On the FTA's evolving regime.

Field notes on UAE Corporate Tax, Transfer Pricing and international tax — written for finance leaders who need the implication, not the press release.

Transfer Pricing

UAE TP Framework-Basic Thresholds

For businesses operating in the UAE, Transfer Pricing (TP) has evolved from a best-practice recommendation to a mandatory compliance pillar under the Corporate Tax regime. Below is an overview of the regulatory requirements, documentation thresholds, and reporting obligations.

10 min
Transfer Pricing

LVAS-5%? can we apply it in UAE

The UAE Federal Tax Authority (FTA) follows the Arm's Length Principle (ALP), which requires that all related-party transactions be priced as if they were between independent parties. Here is how you should interpret the "5% rule" in the UAE

5 min
International Tax

Pillar 2-DMTT

The UAE’s implementation of Pillar Two is not merely a policy suggestion; it is a legally codified regime

5 min
Transfer Pricing

Transfer Pricing Shift: From Policy to Performance

As we enter the 2026 tax cycle, FTA has made it clear: Transfer Pricing (TP) is the new focal point for compliance and audits.

5 min
Transfer Pricing

interquartile range-25th to 75th percentile- considered arm’s length.

According to both OECD guidelines and the UAE Transfer Pricing framework, any result that falls within the interquartile range (25th to 75th percentile) is considered arm’s length.

5 min
Transfer Pricing

Interest Rate Benchmarking under UAE Corporate Tax Law

Intra-group financing arrangements are under increasing scrutiny to ensure compliance with the arm’s length principle.

5 min
Transfer Pricing

Choose the Right PLI for Imports under TNMM:

Which Profit Level Indicator (PLI) is most suitable when testing the arm’s length nature of purchases/import of good

3 min
Transfer Pricing

Currency Depreciation & Transfer Pricing — Legal Justification for Intercompany Price Adjustments

Currency Depreciation & Transfer Pricing — Legal Justification for Intercompany Price Adjustments

5 min
General

UAE VAT on Director's Services

FTA has clarified how VAT applies to Director services

5 min
Transfer Pricing

The "Salary Survey" Trap: Why Benchmarking Fails UAE Directors

To comply with Article 36 of the UAE Corporate Tax Law, I see a dangerous trend emerging: the blind reliance on "Salary Surveys" to justify Connected Person remuneration.

5 min
Compliance

What changes on 1 January 2026 — refunds, audit windows and you

The FTA's 2026 procedural updates tighten refund limits and extend audit periods. Here's what it means for your documentation calendar.

6 min
Transfer Pricing

The FTA's APA programme — who should apply, and when

The Advance Pricing Agreement programme offers 3–5 years of certainty. Whether it's right for you depends on your transaction profile.

5 min
International Tax

Holding your 0% — substance and TP for Qualifying Free Zone Persons

The 0% Free Zone rate is conditional. Substance and transfer pricing alignment are what keep it.

7 min
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