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

GCC TP Strategy for Healthcare and Pharmaceuticals

The pharmaceutical and healthcare sectors represent the ultimate frontier of Transfer Pricing (TP) complexity, where value chains are characterized by extreme risk-taking, prolonged capital lock-ups, and the dominance of intangible assets. In this high-stakes environment, the traditional reliance on physical asset accounting is obsolete.

5 min
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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