Client Profile (Anonymised)
- Client Type / Stage: Multinational group subsidiary (developing–developed transition stage)
- Ownership: Part of a Norway-based multinational group
- Annual Turnover (UAE Entity): Approx. USD 30 million
- Geographic Footprint: UAE with cross-border group linkages
- Industry: Oil & gas–related technical services and specialist manpower support
- Operating Model: Group-integrated operations with local regulatory and governance obligations
Background & Context
With the introduction of UAE Corporate Tax, multinational groups operating through UAE Free Zone entities faced a new level of scrutiny—particularly around controlled transactions, arm’s length pricing, and governance substance.
While the group had established global accounting, audit, and tax practices, the UAE entity required localised interpretation, execution, and defensibility under UAE Corporate Tax Law, aligned with OECD principles.
The challenge was not compliance in isolation but ensuring that the UAE entity could withstand tax authority review while remaining fully aligned with group policies—without fragmenting responsibility across advisors.
Key Challenges Identified
- Application of the Arm’s Length Principle to UAE-specific controlled transactions
- Identification and evaluation of unique inter-company transactions
- Translating OECD Transfer Pricing principles into UAE Corporate Tax–compliant execution
- Risk of over-reliance on individuals rather than institutional processes
- Ensuring audit, accounting, and tax practices remained consistent yet locally defensible
- Creating governance documentation acceptable at both UAE and group levels
Engagement Objectives
- Establish full UAE Corporate Tax compliance with defensible arm’s length positions
- Perform benchmarking analysis for controlled transactions
- Align local practices with OECD guidelines as embedded in UAE CT law
- Reduce tax and governance risk exposure for the group
- Build a process-driven compliance framework, not a person-dependent one
The Total CFO’s Structured Intervention
- Arm’s Length Evaluation & Benchmarking Framework
A detailed review of controlled transactions was undertaken, including:
- Identification of transaction types requiring arm’s length testing
- Evaluation of transaction uniqueness and functional profiles
- Application of OECD-aligned principles as adopted under UAE Corporate Tax
- Benchmarking analysis to support pricing and policy positions
This ensured that the UAE entity’s inter-company dealings were defensible, documented, and regulator-ready.
- Local Compliance Ownership within a Multinational Environment
Despite being part of a multinational group, all UAE local compliance matters were entrusted to a boutique advisory firm—a deliberate and confidence-driven decision.
This extended beyond Corporate Tax to include:
- Accounting interpretations
- Audit pre-alignment and audit support
- Regulatory positioning under UAE law
The engagement evolved from advisory support to trusted local stewardship.
- Governance & Internal Control Architecture
A comprehensive internal governance and compliance document (AOA-aligned internal procedures) was developed, covering:
- Compliance responsibilities
- Board and AGM processes
- Delegation frameworks
- Regulatory and reporting controls
This documentation was reviewed, accepted, and appreciated at group level, reinforcing confidence in the UAE control environment.
- Checklist-Driven Compliance & Risk Control
A structured compliance register and checklist-based system was implemented to:
- Track Corporate Tax, AML, regulatory, and governance obligations
- Reduce dependency on specific individuals
- Ensure continuity despite staff transfers or role changes
Compliance shifted from who handles it to how it is controlled.
Outcomes & Business Impact
Qualitative Outcomes
- Significant mitigation of Corporate Tax and transfer pricing risk exposure
- Stronger confidence at group level in the UAE entity’s compliance posture
- Clear, defensible arm’s length documentation supporting controlled transactions
- Institutionalized processes replacing individual dependency
Strategic Outcomes
- A single, accountable point of control for UAE Corporate Tax matters
- Alignment between global group practices and UAE regulatory expectations
- Enhanced audit and regulatory readiness without operational disruption
Strategic Takeaway
For multinational groups, UAE Corporate Tax compliance is not about filing returns, it is about defensibility, governance, and trust.
This engagement demonstrates that when arm’s length principles, benchmarking, and internal controls are handled with precision, local compliance becomes a strength rather than a risk point, even within complex group structures.
Why This Matters for Similar Businesses
If your UAE entity:
- Is part of a multinational group
- Undertakes controlled inter-company transactions
- Faces arm’s length and substance scrutiny
- Relies heavily on individuals rather than systems
Then Corporate Tax risk is often latent, not visible. The answer lies in process, documentation, and local ownership, not scale of advisor.