Strategic Advisory

Documentation records and defends pricing that already exists, prepared contemporaneously for the FTA to review on request. Strategic Advisory happens before that — modelling what the pricing or structure should be, presenting options to the Board, and producing a recommendation and policy that the documentation team then builds the annual Local File around. Many clients need both, sequenced together, but they are scoped and delivered as distinct pieces of work.

Before. Once the agreement is signed and the arrangement operates on its terms, correcting the pricing retroactively is far more constrained than designing it correctly from the outset — the financial statements for the period cannot be reopened, and a mid-course correction reads differently to a reviewer than pricing that was arm's length from day one. Strategic Advisory is specifically designed to be engaged before terms are finalised.

Yes — this is one of the most common uses of the engagement. For example, choosing between a direct sale to a related distributor versus a limited-risk distributor model versus a commissionaire structure each carries a different FAR profile, a different appropriate pricing method, and a different arm's length outcome and Corporate Tax result. PNPC models the viable options side by side so the Board can weigh the trade-offs rather than defaulting to whichever structure was easiest to set up operationally.

A Free Zone entity's related-party dealings with mainland or foreign affiliates can, if mispriced or simply if related-party income grows as a proportion of total revenue, push non-qualifying revenue past the permitted de minimis threshold for Qualifying Income — putting the entire 0% QFZP rate at risk, not just the specific transaction. Strategic Advisory models this exposure ahead of a new arrangement or a material change in related-party volume, so the structure can be adjusted while it is still a design decision rather than a completed year that has to be lived with.

As early as the target's structure and intercompany relationships are known, ideally during due diligence rather than after signing. An acquisition changes the group's related-party map — new entities become related parties, existing pricing policies may no longer fit the combined structure, and any transfer pricing exposure sitting inside the target becomes the acquirer's problem post-completion. Modelling this before close gives the acquirer negotiating leverage and time to plan remediation; discovering it after close leaves only remediation.

Yes. This is a common trigger — a group reviews its own structure and suspects an intercompany arrangement set years ago for cash-flow or administrative convenience was never actually tested against the arm's length standard. Strategic Advisory in this scenario assesses the exposure, models corrective options (prospective policy change, and separately, whether historical periods warrant remediation or voluntary disclosure), and lays out the trade-offs for management to decide, rather than PNPC deciding unilaterally what to do about the past.

Yes. Where a group is designing a new shareholder loan, intercompany financing arrangement, or guarantee structure, Strategic Advisory models the appropriate interest rate, tenure, and terms against what an independent lender would charge given the borrower's credit profile — before the loan is drawn — rather than testing an existing loan's terms retrospectively as part of annual documentation.

We model both sides together rather than sequentially. Most GCC states, including Saudi Arabia under its ZATCA rules, and jurisdictions like India under Section 92 of the Income-tax Act, have their own transfer pricing regimes that closely track OECD guidance but are not identical in every respect. Strategic Advisory for a cross-border arrangement identifies where the two jurisdictions' expected outcomes would diverge and recommends a position defensible under both, rather than optimising for one side and hoping the other does not query it.

A framing of the decision being made, the related-party and FAR analysis for each structuring option considered, the pricing method and indicative arm's length range for each option, the Corporate Tax and (where relevant) QFZP consequences of each, a clear recommendation, and the basis for it. It is written for the Board or senior management to make an informed decision, not as a compliance document for the FTA — though its analysis typically feeds directly into the next annual Local File once the decision is implemented.

Yes. Where an informal question or an inconsistency flagged during return processing has surfaced but has not yet escalated to a formal information request, there is often a strategic choice about how to respond — clarify factually, proactively provide supporting analysis, or treat it as a signal to get ahead of a fuller review. PNPC assesses the technical merits and advises on the most effective response strategy at this earlier, less adversarial stage.

Strategic Advisory typically includes an indicative benchmarking range to inform the structuring decision — enough to confirm the proposed pricing is directionally defensible — but a full, formally screened benchmarking study with a documented comparable set and rejection matrix is usually run as part of the subsequent documentation engagement, once the structure is finalised and ready to be evidenced to the FTA. PNPC scopes the two separately so clients are not paying for full benchmarking rigour on options that may not ultimately be selected.

Where a proposed structure or an existing arrangement risks a cross-border adjustment that is not mirrored by a corresponding adjustment in the counterparty jurisdiction, PNPC assesses whether a Double Taxation Avoidance Agreement between the UAE and that jurisdiction provides for a MAP, and advises on whether pursuing it is proportionate given its typically longer timeline, against simply avoiding the adjustment risk through better upfront structuring.

It depends on whether a genuine decision is pending. A small group with stable, already-benchmarked pricing and no planned changes has little need for ongoing strategic advisory beyond the annual documentation refresh. A small group about to set up its first intercompany management arrangement, or converting one entity to a Free Zone structure, benefits from the same upfront modelling as a larger group — the scale of the analysis is proportionate to the group's complexity, but the value of getting a new arrangement right from the outset does not disappear because the group is small.

PNPC scopes and quotes a fixed fee based on the number of structuring options to be modelled, whether cross-border jurisdictions are involved, and whether the engagement includes formal Board presentation and policy drafting or ends at the recommendation memo stage — agreed in writing before work begins, consistent with how PNPC prices transfer pricing documentation engagements.