Transfer Pricing & Permanent Establishment
international tax for MEA operations.
International tax advisory for multinational businesses with UAE and KSA operations — covering permanent establishment (PE) risk assessment, transfer pricing documentation for related-party transactions, and BEPS compliance under UAE and KSA tax frameworks.
Dubai · Abu Dhabi · Tokyo
What the international tax service covers.
Assessment of whether UAE or KSA operations create a PE for the parent company — under the applicable bilateral tax treaty or domestic PE rules.
Preparation of transfer pricing documentation for related-party transactions between the UAE/KSA entity and group entities — meeting UAE CT law and KSA GAZT/ZATCA requirements.
Review and drafting of intercompany agreements — management service fee agreements, royalty agreements, cost-sharing arrangements — to support transfer pricing positions.
Assessment of UAE Domestic Minimum Top-up Tax (DMTT) exposure under the Pillar Two global minimum tax rules for large multinational groups.
Support for Country-by-Country (CbC) reporting obligations — including notification filing and CbC report preparation for groups with UAE or KSA constituent entities.
Advice on the application of UAE and KSA bilateral tax treaties — including treaty access, withholding tax rates, and treaty-based PE definitions.
How an engagement works.
Understand the group structure, intercompany flows, and UAE/KSA operational footprint to identify PE and transfer pricing risks.
Assess the PE risk arising from UAE/KSA operations under applicable treaty or domestic rules. Identify structural changes to mitigate risk where appropriate.
Apply the arm's length principle to intercompany transactions — selecting the appropriate transfer pricing method and benchmarking.
Prepare the transfer pricing documentation file — master file, local file, and benchmarking study — to the required standard.
File required notifications and maintain documentation for the prescribed retention period.
Markets we cover.
How we differ.
- PE risk not assessed until the tax authority raises an inquiry
- Transfer pricing documentation not prepared — penalties for non-compliance
- Intercompany agreements not in place or not arm's length
- DMTT exposure for Pillar Two not assessed
- Tax treaty benefits not claimed — higher withholding tax paid unnecessarily
- PE risk assessed at structure design stage — issues addressed before they arise
- Transfer pricing documentation prepared annually to UAE CT and KSA GAZT standards
- Intercompany agreements reviewed and aligned to transfer pricing positions
- DMTT and Pillar Two exposure assessed for qualifying large groups
- Tax treaty advisory integrated into structure and transaction planning
UAE and KSA operations.
PE risk, transfer pricing, DMTT — by a team that understands the UAE and KSA tax framework. The initial consultation is free of charge.