Trade in three countries. Get taxed once.
The moment a business has a customer, an employee or a company in a second country, three questions appear: which entity earns the profit, at what price do the entities deal with each other, and does anything create a taxable presence you did not intend. We answer them in advance.
The whole job, not the visible half.
Everything below is in scope on the plan that includes international tax & transfer pricing. Nothing on this list is an add-on.
- Group structure review: which entity should own what, and where profits should sit
- Transfer pricing policy and documentation: master file, local file and benchmarking
- Permanent establishment risk assessment for remote staff and sales activity
- Double tax treaty analysis and relief claims, including the UK-UAE and UK-US treaties
- Withholding tax on dividends, interest, royalties and service fees
- Profit repatriation: dividends, management charges and loans, modelled for tax cost
Three situations we see every week.
UK or US companies opening in the UAE
A UAE subsidiary at 9 percent, or 0 percent in a qualifying free zone, is attractive only if the profit genuinely sits there. Substance and transfer pricing decide whether it does.
UAE companies selling into the UK or US
Sales activity, a warehouse or a dependent agent can create a taxable presence and a filing obligation without any company being formed.
Founders who have moved country
Where the founder is resident changes where the company is managed from, which can change where it is taxed.
Four steps, then a rhythm.
Map
Every entity, every intercompany flow, every person and where they sit. Most risks are visible on the map.
Policy
A transfer pricing policy for each flow: management services, IP, financing, goods. Priced at arm's length with the evidence to support it.
Document
Master file, local files and the disclosure forms each country requires, kept current.
Monitor
Annual review of the map against changes in staff, sales and law.
The rules differ. So does the work.
The same service, applied to each jurisdiction's law. Figures checked September 2026.
Transfer pricing rules apply to large groups in full and to SMEs where dealings are with non-treaty or low-tax territories, which includes the UAE for some purposes. The diverted profits regime and the 2024 changes to the corporate interest restriction add further tests.
Everything about the UK ↗The Corporate Tax Law adopts OECD transfer pricing principles for all related-party transactions. A disclosure form accompanies the return, and a master file and local file are required above AED 200 million of revenue or for members of large multinational groups.
Everything about the UAE ↗Section 482 transfer pricing rules apply to all controlled transactions, with penalties reduced by contemporaneous documentation. Form 5471 and 5472 reporting captures the flows, and the 2025 legislation retained the GILTI and FDII regimes in modified form.
Everything about the USA ↗One senior accountant. One flat fee. Three countries.
Group figures are Shaazford Global LLC's published numbers across all its service lines.
Is a UAE company the answer to UK tax?
Only if it has real substance and real activity in the UAE. A UAE company managed from the UK is UK-resident for tax. The structure has to match where the people and decisions are.
Do I need transfer pricing documentation as a small group?
The UAE requires arm's-length pricing for every related-party transaction regardless of size, with formal files above thresholds. The UK and US have SME relaxations with exceptions. A short policy document is cheap insurance for any group.
What creates a permanent establishment?
A fixed place of business, or a person who habitually concludes contracts on the company's behalf. A remote sales employee in the UK for a UAE company is the classic trigger.
Can I move my company to the UAE?
Migration is possible but is a taxable event in the departing country, with exit charges on unrealised gains. Usually a new UAE entity with a transfer of specific activity is cleaner. We model both.
Talk to us about international tax & transfer pricing.
Thirty minutes, no pitch deck. Tell us the entities and the countries, and we will tell you honestly what applies and what it costs.