UAE Law and Practice Contributed by: Marios Palesis, Theodora Charalambous and Giorgos Kinanis, Kinanis Tax Consultancy Middle East Limited
15.2 Restrictions on Outbound Payments Relating to Controlled Transactions The UAE does not restrict outbound payments relating to controlled transactions, provided such payments are made wholly and exclusively for the production of taxable income and are at arm’s length. 15.3 Effects of Other Countries’ Legal Restrictions The UAE does not have rules regarding the effects of other countries’ legal restrictions. 16. Transparency and Confidentiality 16.1 Publication of Information on APAs or Transfer Pricing Audit Outcomes The UAE does not currently publish information on
of full payment of the disputed tax as well as at least 50% of any administrative fines (or a bank guarantee) for the appeal to be admissible. 14. Judicial Precedent 14.1 Judicial Precedent on Transfer Pricing The UAE transfer pricing regime became effective in 2023. Therefore, judicial precedent on transfer pricing in the UAE does not yet exist. 14.2 Significant Court Rulings As the UAE’s transfer pricing regime became effective in 2023, there are no court rulings yet. 15. Foreign Payment Restrictions 15.1 Restrictions on Outbound Payments Relating to Uncontrolled Transactions The UAE does not restrict outbound payments relating to uncontrolled transactions, provided such payments are incurred wholly and exclusively for the production of taxable income.
APAs or transfer pricing audit outcomes. 16.2 Use of “Secret Comparables”
The Corporate Tax Law allows the FTA to rely only on information that can or will be made available to the taxpayer.
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