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Transfer pricing – as a pragmatic tool to measure ‘the Adequacy’ under the UAE’s Economic Substance Regulations

19 Aug, 2021

Transfer pricing – as a pragmatic tool to measure ‘the Adequacy’ under the UAE’s  Economic Substance Regulations

Sarika Dhameja

- Head of Tax, PKF UAE

Transfer pricing – as a pragmatic tool to measure ‘the Adequacy’ under the UAE’s  Economic Substance Regulations

Vinit Kamlesh Gala

- Assistant Manager - Tax Services, PKF UAE


Demonstrating the Economic Substance in the UAE for all the in-scope entities is now a reality. In this relation, there are three tests prescribed in the UAE’s Economic Substance Regulations which need to be satisfied cumulatively in order to demonstrate appropriate Economic Substance in UAE.

The ‘adequacy’ test is one of the three tests, which in simple terms, emphasizes on having ‘adequate’ locally present employees, locally incurred operating expenditure and..


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