While transfer pricing regulations have not been issued in the region to date, apart from Egypt, Deloitte Middle East's transfer pricing advisors say that tax authorities in several GCC countries have started to be receptive to taxpayers, providing transfer pricing documentation to support the arm's length nature of related party transactions. Transfer pricing refers to the setting, analysis, documentation, and adjustment of charges made between related parties for goods, services, or use of property (including intangible property). Transfer prices among components of an enterprise may be used to reflect allocation of resources among such components, or for other purposes. OECD Transfer Pricing Guidelines state "transfer prices are significant for both taxpayers and tax administrations because they determine in large part the income and expenses, and therefore taxable profits, of associated enterprises in different tax jurisdictions." Accordingly, Deloitte Middle East's transfer pricing advisors have undertaken transfer pricing reviews in the majority of GCC countries and expect detailed transfer pricing regulations to be issued in the near future, as each respective Tax Authority develops their own approach and preferences in relation to transfer pricing. In light of its expertise in the transfer pricing field, Deloitte member firms across the globe were recognized for the sixth consecutive time, by Euromoney's 2011 Guide to the World's Leading Transfer Pricing Advisers, as having the highest number of leading transfer pricing advisers. Ninety-six Deloitte member firms' tax partners in 40 jurisdictions were included in the 2011 guide as leading transfer pricing advisers. "These awards recognize the Deloitte network's top transfer pricing advisers, who are well- respected among clients and peers and who serve our clients across geographies," said Nauman Ahmed, partner in charge for Tax Services at Deloitte in the Middle East. "We believe this recognition also reflects Deloitte's ongoing commitment to excellence in the area of transfer pricing," he added. Deloitte's tax advisors help clients understand, plan for, and deal with the complex and dynamic issues surrounding transfer pricing. Deloitte's comprehensive services include improving tax efficiency and defense posture, resolution of global transfer pricing controversies, and strategic documentation. At Deloitte Middle East, transfer pricing experts have assisted global organizations working in Middle East in setting up and implementing suitable related party pricing structures and transfer pricing documentation requirements. These efforts have been carried out to meet both tax authority requirements and those imposed by other stakeholders such as local auditors and overseas affiliates. "Our added value to clients is in helping them interpret the transfer pricing regimes and guidelines in a way which is suitable both for the client's business and in the context of the local legislation. In doing so we look to leverage from Deloitte's local and global transfer pricing expertise to ensure robust local compliance and to enhance client-side understanding of how Middle East transfer pricing regulations impact their business," said Ali Kazimi, Deloitte Middle East's regional managing director for International Tax Services. The process for selecting the leading transfer pricing tax advisers is extensive. More than 4,000 senior practitioners and in-house tax directors in 65 jurisdictions are sent a questionnaire requesting nominations for leading practitioners based on their work and reputation. The results are then analyzed and screened for firm, network, and alliance bias. The list of experts is then discussed and refined with advisers in legal centers worldwide. The Guide to the World's Leading Transfer Pricing Advisers is published biannually by Legal Media Group.
