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transfer pricing

Our experts provide a full range of services related to the application of transfer pricing legislation in relation to goods, services and intangible assets
All transactions between related (connected) parties are potentially AT risk of TP control
Taxpayers should be ready to justify prices applied in transactions with such counterparties
The choice and application of a TP method should be justified
The tax authority may require a taxpayer to file a TP documentation together with a tax return
And, in certain cases three-tier TP documentation.
Planning the pricing of a transaction in advance is a reliable tool for managing TP risks
There is liability for breach of TP regulations
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Important

PLEASE READ CAREFULLY
On 9 December 2022, the United Arab Emirates (UAE) Ministry of Finance (MoF) released Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses (Corporate Tax Law or the Law) to enact a new corporate tax (CT) regime in the UAE. The Corporate Tax Law will be effective from 1 June 2023 with a headline rate of 9%.
WE ARE TRUSTED BY 100+ COMPANIES FROM DIFFERENT INDUSTRIES

services

ADE Professional Solutions assists with transfer pricing tasks
Important information

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/

Obligations of taxpayer

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).

Brief explanation of the concept

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.


ACCA PLATINUM APPROVED EMPLOYER SINCE 2010
Employees are required to study under the ACCA program and more than 100 employees have completed ACCA training over the past 10 years.
International status

Since 2021, a member of the Russian-German Chamber of Commerce.

Since 2021, he has been a member of the HLB Global international network, part of the Forum of Firms.

International status

ADE Professional Solutions, according to the results of World TP 2020, entered Tier 3 in the direction of Transfer Pricing

RAEX ratings
Since its participation in the ranking, ADE Professional Solutions has been gradually moving up to the top lines among consulting companies. We are particularly proud of our position in the IFRS accounting outsourcing ranking, where we are highly qualified. In this direction, we are not only always among the leaders in terms of the volume of services, but also focus on exceptional quality.
RAEX ratings

For the last 5 years, it has been steadily occupying a position in the TOP-10 for such services as accounting outsourcing in accordance with IFRS and transfer pricing. 27th place in the ranking of Tax consulting (Except RA, 2021)

TOP 2
Financial reporting outsourcing
TOP 20
Major financial advisors
TOP 100
The largest consulting companies

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TEAM

Our specialists have significant experience in transfer pricing tasks and are ready to promptly assist you.
Dmitry Sklyarov
Partner, FCCA, ACFE
Tatyana Voronina
Director, Transfer pricing and tax services
Sofia Morozova
Senior tax consultant
Nika Slavinskaya
Tax consulting Practice manager
Sofia Mashkova
Junior manager, lawyer
Tokar Kseniya
Tax consultant
KEY BENEFITS OF WORKING WITH ADE PROFESSIONAL SOLUTIONS
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Our company has been dealing with the business processes and management consulting since 2006, and key specialists of our company have been actively involved since 1997.
We have assisted more than 1,000 clients from all over the world operating in diverse industries to overcome complex business issues.
We have successfully completed management consulting projects in the Russian Federation, Kazakhstan, Great Britain, Romania, China, the Netherlands, the USA, Venezuela and many other countries.
We regularly accompany projects with all Big Four companies.
Our clients value us for quality, professionalism, efficiency and flexibility in work.
We have assisted with business processes and IPO preparation for companies entering the capital markets (IPOs) in challenging markets like the London Stock Exchange (LSE).
As methodologists, we are ready to accompany the Client in complex business issues including business process restructuring, taxation, reporting and audit.
Our specialists have the following professional competences: CIA, ACFE, ACCA. Our company is an ACCA Platinum Approved Employer.
Customer Reviews
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A.O. Poznyak
Deputy General Director for Finance

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.

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A. Gryaznykh
Director of the Taxation Department

JSC (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. Ginzburg
CEO, Chairman of the Management Board

LLC "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. Shvetsova
Director of Finance and Administration

A.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. Zege
Head 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. Kalabin
General manager

A.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. Ignatiev
General manager

A.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. Gorkov
General manager

A.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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