International Tax & Transfer Pricing Advisory

VBS provides senior-led international tax and transfer pricing advisory for businesses with cross-border operations, related-party arrangements, overseas ownership, investment flows, or group structures. We help you reduce uncertainty, avoid structural surprises, and document positions properly — so decisions are commercially practical and defensible.

Common triggers we help with

Expanding operations across borders

Overseas shareholders or investment structures

Contracts signed offshore or services delivered across jurisdictions

Holding company and redomiciliation questions

Related party charges, management fees, or intragroup loans

Why this matters

International tax and transfer pricing issues rarely appear all at once. They usually build through contract terms, where decisions are made, how people operate, how cash moves, and how related parties charge each other.

Our advisory begins with the commercial reality behind the structure and transactions. From there, we help translate that reality into a position that is practical to operate, consistent with the records, and supported by documentation.

International Tax & Cross-Border Advisory

Cross-border tax advisory

International tax becomes important when ownership, management, income, or operations cross borders. VBS supports businesses that need clarity on tax exposure, treaty positioning, substance, residency, and structuring decisions.

Treaties, withholding, and
cross-border payments

We support withholding tax advisory where payments, contracts, services, or investment flows involve overseas counterparties. This includes reviewing double tax treaty UAE considerations where treaty access, relief, or residency positioning may be relevant.

Establishment and management risk

Cross-border activity can create exposure when people, contracts, or decision-making create a taxable presence. VBS supports permanent establishment UAE risk reviews based on activity, contracting, execution, and commercial substance.

We also review place of effective management considerations, especially where management and control may influence tax outcomes, and assess foreign company UAE tax exposure where an overseas business has local nexus or market-facing activity.

Residency, redomiciliation, and
holding structures

VBS supports clients with tax residency certificate UAE positioning and documentation readiness where relevant. We also provide practical guidance on redomiciliation UAE tax considerations and what changes operationally when entities move or restructure.

For ownership and investment planning, we advise on holding company tax UAE considerations, governance, and defensibility — especially where holding structures are used for regional or cross-border investment planning.

Substance and participation exemption

Tax positions need to be supported by facts, not just structure charts. We help clients understand substance requirements UAE and what substance looks like in practice: decision-making, documentation, governance, operational evidence, and records.

Where applicable, we also support positioning around participation exemption, ensuring the analysis is tied to the facts and documentation available.

High-risk areas we commonly review

International tax risk areas

Overseas contracting arrangements
Management and control across jurisdictions
Cross-border payments and withholding considerations
Foreign company activity and local nexus
Holding company and redomiciliation structures
Substance and participation exemption positions

Transfer pricing risk areas

Management fees and shared service charges
Intragroup loans and financing arrangements
Intercompany service charges
Intercompany service charges
Agreements that exist on paper but not in operations
Disclosure data that does not match accounting records

Transfer Pricing & Related Party Compliance

Transfer pricing support built for repeatable compliance

Transfer pricing risk is rarely about whether a charge exists. It is about whether the rationale, pricing logic, and evidence are consistent — and whether the documentation matches how the arrangement works in practice.

VBS supports transfer pricing UAE engagements with a clear objective: build related-party positions that can be explained, evidenced, and repeated year after year.

Related parties, connected persons, and risk mapping

We start by mapping related party transactions across services, fees, financing, asset use, and group arrangements. Where relevant, we also review exposure areas involving connected persons UAE.

From there, we evaluate how each arrangement supports the arm’s length principle based on what is actually delivered, who benefits, and why the pricing is commercially justified.

Documentation and compliance deliverables

VBS supports transfer pricing documentation that reflects operations and governance — not generic templates.

Where applicable, we support readiness for local file UAE and master file UAE, and help ensure the underlying data is consistent for the transfer pricing disclosure form.

Pricing logic, benchmarking, and agreements

Where benchmarking is required or useful, we support benchmarking study UAE work to strengthen pricing logic and supportability.

We also draft or review intercompany agreements so legal form matches commercial reality, and provide focused reviews for common risk areas such as management fees transfer pricing and intragroup loans transfer pricing.

Standards and Corporate Tax alignment

Our work is aligned with OECD transfer pricing guidelines in a practical, implementable way. We also support UAE Corporate Tax transfer pricing expectations, especially consistency between agreements, accounting records, disclosures, and supporting documentation.

What you get from VBS

A VBS engagement is designed to give you clarity, structure, and documentation discipline — not just technical commentary.

Cross-border advisory outputs

Clear risk map showing where exposure can arise

Defensible position summary: what applies, why, and what supports it

Practical documentation checklist tied to transaction flow

Decision-ready recommendations that can be implemented and maintained

Transfer pricing outputs

Inventory of related-party arrangements and risk areas

Defensible pricing narrative and evidence expectations

Agreements and documentation aligned to operations

Benchmarking or documentation support where relevant

Clear next steps: what to fix now vs what to monitor

Need clarity on international tax or transfer pricing risk?

Speak with VBS for senior-led advisory that helps you structure, document, and defend cross-border tax and related-party positions.

How we work

01 Understand the facts

We review contracts, ownership, people, governance, cash flows, related-party arrangements, and documentation.

02 Identify tax and pricing risk points

We assess treaty, withholding, permanent establishment, substance, management/control, related-party, and connected-person considerations.

03 Define the position

We develop a practical approach supported by reasoning, records, and evidence requirements.

04 Document clearly

We prepare or support documentation, agreements, narratives, checklists, benchmarking, and disclosure readiness where relevant.

Who this is for

This service is suitable for:

UAE businesses with overseas activity

Companies selling, contracting, investing, or operating across borders.

Groups with related-party transactions

Businesses with management fees, service charges, loans, or shared functions between related entities.

Foreign companies with UAE exposure

Overseas companies with local contracts, people, management activity, or market-facing operations.

Holding and investment structures

Founders, family offices, investment vehicles, and groups planning ownership, redomiciliation, or holding structures.

Businesses preparing for Corporate Tax compliance

Companies that need documentation discipline before filing, disclosure, audit, or authority review.

Cross-border group structures

Businesses with parent companies, subsidiaries, branches, or ownership links across multiple jurisdictions that need clearer tax, transfer pricing, and reporting alignment.

Why VBS

Clients choose VBS because our advisory is:

01 Senior-led

technical decisions are handled with accountability

02 Commercially practical

Advice reflects how the business actually operates

03 Documentation-driven

Positions are supported by records and evidence

04 Governance-focused

Designed for consistency, not one-off fixes

FAQs

Common Questions

Quick answers about our accounting support and monthly deliverables.

Do you advise on cross-border structuring and international tax?

Yes. We focus on practical cross-border decisions — what you can implement, maintain, and defend.

Can you assess permanent establishment risk?

Yes. We assess permanent establishment risk based on contracts, people, activity patterns, and local nexus.

Do you support tax residency positioning?

Yes. We support documentation readiness for tax residency certificate applications where relevant.

Do you help with related party and connected person reviews?

Yes. We review related party transactions and connected person exposures with practical governance steps.

Can you support local file and master file readiness?

Yes. We support local file and master file readiness where applicable, along with transfer pricing documentation and disclosure form consistency.

Do you assist with benchmarking and intercompany agreements?

Yes. We support benchmarking studies where relevant and help draft or review intercompany agreements so they reflect the commercial arrangement.

GET IN TOUCH

Let’s Discuss Your Business Needs

Connect with our advisors for customized accounting, tax, audit, and business setup
solutions tailored to your goals.

Get in Touch

Phone

+971 4 331 4099

Email

floricar@vbs.ae

Corporate Office

Office No. 219, Al Goze Building, Sheikh Zayed Road, Al Quoz 1, Dubai, UAE