CJSC "Moscow Brewing Company" has been cooperating with LLC "A.D.E. Accounting" on transfer pricing issues since 2017.
We can confidently recommend A.D.E. Accounting LLC as a reliable and responsible partner.
The Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses (Corporate Tax Law) was issued in United Arab Emirates (UAE) on 9th December 2022, providing a full new corporate tax system for UAE, including introduction of the federal corporate tax at basic tax rate of 9% and other matters connected to corporate taxation (domestic and international ones)[1]. The Federal Decree-Law is effective for financial years starting on or after June 1st, 2023.
Since basic corporate tax rate of 9% is one of the lowest rates worldwide, and UAE as a trading hub and a commercial center is gaining its popularity with MNEs (multinational entities), a risk of tax base erosion and profit shifting arises.
To address these concerns, the Corporate Tax Law has also introduced commonly used international tax instruments, including transfer pricing (TP) rules. The rules are designed closely to OECD TP Guideline.
[1] An overview of its provisions can be found on UAE Ministry of Finance official website:
https://mof.gov.ae/corporate-tax/
A prison sentence and a monetary penalty not less than the amount of evaded tax and not exceeding (3) three times of it, or either of the two, shall be imposed on any person who has committed tax evasion by deliberately decreasing the due tax or participating in any form of Tax evasion (Article 25 of the Federal Decree-Law No. 28 of 2022 on Tax Procedures (issued September 30th, 2022, effective from March 1st, 2023).
Transfer pricing rules are commonly used to ensure that prices in intragroup transactions are arm’s length, i.e. are at the market level. The main purpose of these rules is to prevent tax avoidance by shifting transactional profits to a jurisdiction with a lower tax burden.
The core base of TP regulation is an arm’s length principle, which means the results of the transaction or arrangement are consistent with the results that would have been realised if the parties to the transaction were not related parties and had engaged in a similar transaction or arrangement under similar circumstances.
To prove that the financial results of the transaction meet the arm’s length, it is compared with the market prices or profitability using TP methods or its combination. Commonly a TP documentation (Local file) is prepared to justify the market level of the prices in the controlled transactions. The TP documentation usually contains the description of a transaction, procedure of analysis, rationale for the method choice and results of its application, and is further presented to the tax authorities by request or along with reporting.
A.O. PoznyakDeputy General Director for FinanceCJSC "Moscow Brewing Company" has been cooperating with LLC "A.D.E. Accounting" on transfer pricing issues since 2017.
We can confidently recommend A.D.E. Accounting LLC as a reliable and responsible partner.
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A. GryaznykhDirector of the Taxation DepartmentJSC (N) Volvo Vostok has been cooperating with A.D.E. Professional Solutions LLC on various transfer taxation issues since 2013.
As a customer, we highly appreciate the timeliness and quality of the work performed and can confidently recommend A.D.E. Professional Solutions LLC as a reliable partner.
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Y.B. GinzburgCEO, Chairman of the Management BoardLLC "INC" during 2020-2022 cooperates with LLC "A.D.E. Professional Solutions" on issues related to the application of legislation on transfer pricing.
We recommend A.D.E. Professional Solutions LLC as a reliable, responsible partner in transfer pricing and corporate taxation.
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E.V. ShvetsovaDirector of Finance and AdministrationA.D.E. Professional Solutions LLC has been providing support to Ritter Sport Chocolate LLC on transfer pricing issues since 2020.
We can confidently recommend A.D.E. Professional Solutions LLC as a reliable and responsible partner in the field of TP and corporate taxation.
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O.S. ZegeHead of OP in LLC "Doppelmair Rush"A.D.E. Professional Solutions LLC provides support to Doppelmair Rush LLC on transfer pricing issues.
We can confidently recommend A.D.E. Professional Solutions LLC as a reliable and responsible partner in the field of TP and corporate taxation.
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Y.V. KalabinGeneral managerA.D.E. Professional Solutions LLC has been providing transfer pricing support to Paul Hartmann LLC since 2018.
We recommend A.D.E. Professional Solutions LLC as a responsible company that is attentive to customer requests and competently suited to its work.
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M.L. IgnatievGeneral managerA.D.E. Professional Solutions LLC has been preparing transfer pricing documentation for Hansgroe LLC since 2018.
We recommend A.D.E. Professional Solutions LLC as a qualified contractor and a reliable partner in the field of TP and corporate taxation.
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I.L. GorkovGeneral managerA.D.E. Professional Solutions LLC has been providing support to Nexine JSC on transfer pricing issues since 2020.
We can confidently recommend A.D.E. Professional Solutions LLC as a reliable and responsible partner in the field of TP and corporate taxation.
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