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Read our latest Insights
With 45+ years of experience and 1000+ businesses served across diverse industries, we continue to drive innovation, efficiency, and sustainable growth for organizations worldwide.
We're a leading provider of essential business services to support the global progress of companies and funds.
Here at IMC, our purpose is progress. Learn more
Be in the know with our latest news, insights and analysis
Our Board and Executive Leadership Team
Find out what makes our business and our brand tick
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With 45+ years of experience and 1000+ businesses served across diverse industries, we continue to drive innovation, efficiency, and sustainable growth for organizations worldwide.
International Tax · UAE
Transfer pricing files, Country-by-Country Reporting and the 15% Domestic Minimum Top-up Tax now land on the same finance desk. IMC maps which rules reach each UAE entity in a group and handles them as one coordinated engagement across India, the UAE and Singapore.
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Key Thresholds
Most of a group's international tax position in the UAE follows from four thresholds. Each one is tested on a different figure, which is where groups most often misread their position.
Master file and local file
The UAE entity's own revenue in the tax period
Master file and local file for every UAE constituent entity, plus Country-by-Country Reporting for UAE-headquartered groups
Consolidated group revenue
Transfer Pricing Disclosure Form with the Corporate Tax return
Total related party transactions in the period, with each category above AED 4m reported
15% Domestic Minimum Top-up Tax: registration, calculation and returns
Consolidated group revenue in at least two of the four preceding fiscal years
Thresholds as at October 2026. Each figure is referenced to its Ministerial or Cabinet Decision in the technical summaries below.
Group Profiles
The same rules land very differently on a single free zone trading company and on a regional hub inside a global group. This table matches common group profiles to what applies and where the work starts.
| Group profile | What applies in the UAE | Where IMC starts |
|---|---|---|
| UAE entity below AED 200m, group below AED 3.15bn | Arm's length pricing on every related party transaction; Disclosure Form if flows exceed AED 40m | A light-touch pricing file and signed intercompany agreements |
| UAE entity at or above AED 200m | Master file, local file and Disclosure Form | Functional analysis and benchmarking |
| Qualifying Free Zone Person with related party flows | Arm's length compliance as a condition of the 0% rate | Qualifying status review alongside transfer pricing support |
| Group at or above AED 3.15bn | Documentation for every UAE entity; Country-by-Country Report if UAE-headquartered | Group-wide pricing policy and report alignment |
| Group at or above EUR 750m in two of four years | Top-up Tax registration, effective tax rate calculation and returns | Scope test, entity registration and data readiness |
Our Services
Each service can run on its own, but most groups take two or three together because they draw on the same entity data and the same intercompany story.
Master file, local file, Disclosure Form and benchmarking, built to stand up in the UAE and in the counterparty's jurisdiction.
Transfer pricing documentation in the UAEScope testing, Top-up Tax registration, effective tax rate modelling and return preparation for in-scope groups.
Pillar Two in the UAEAgreements and group pricing policies written to match how each entity actually operates, so contracts and documentation tell the same story.
Holding, mainland and free zone structures reviewed against Corporate Tax, transfer pricing and the 15% floor at the same time.
Report preparation for UAE-headquartered groups, reconciled to the master file and the group's consolidated accounts.
Structured responses to Federal Tax Authority queries on related party transactions, backed by the documentation already on file.
Cross-Border Corridor
Every intercompany transaction has two ends. When an Indian parent charges its Dubai subsidiary for management services, the UAE local file tests the cost and India's Form 3CEB tests the income. Advisers who see only one side tend to produce two analyses that do not quite agree, and that gap is exactly what tax authorities look for.
IMC works across India, the UAE and Singapore as a member of Andersen Global. The functional analysis, comparables and pricing policy are built once and adapted for each authority, so the group presents a single, consistent position wherever it is reviewed.
Groups with a parent in India or Singapore and an operating, holding or free zone entity in the UAE get one team, one data request and one set of numbers.
Technical Library
Two working references for finance and tax teams, each reviewed against the current Ministerial and Cabinet Decisions. Free to download: share a few details and we will email the PDF to you.
Thresholds, file contents, the Disclosure Form and free zone conditions in one reference.
Get the PDF by emailScope test, registration and return calendar, and a readiness checklist for in-scope groups.
Get the PDF by emailFurther reading: IMC's analysis of what the 15% domestic minimum tax means for multinational structures (Mondaq, March 2026).
How We Work
The entity chart and current figures are tested against every threshold, entity by entity.
Related party flows, free zone status and effective tax rate exposure are reviewed together.
Files, agreements, registrations and returns are prepared from one consistent data set.
An annual refresh keeps the position current as figures, rules and structures change.
Get Started
A scoping call with IMC's international tax team walks through the group's thresholds, upcoming dates and the first steps for each UAE entity.
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