Senior Manager - Transfer Pricing

About DAMAC Group

Role purpose

UAE real estate transfer pricing

• Own transfer pricing for property management fees, intercompany financing, shareholder loans, corporate services, construction and development management fees, and sales and marketing services.
• Ensure transactions comply with the UAE Corporate Tax Law and OECD Transfer Pricing Guidelines.
• Draft and maintain intercompany agreements and manage annual UAE related-party disclosure forms.
• Monitor FTA guidance on related-party definitions, including kinship and affinity relationships, and advise the business.

Documentation and advisers

• Prepare and maintain Local File documentation for the Properties business across relevant jurisdictions.
• Coordinate with the Data Centre transfer pricing manager on the group Master File narrative.
• Manage external Big Four benchmarking studies, including briefing, reviewing, and challenging adviser outputs.
• Ensure transfer pricing documentation is updated annually and remains audit-ready.
• Oversee working papers, transaction data, and entity-level profit-and-loss analysis prepared by the India SSC analyst.
• Monitor documentation thresholds and filing deadlines across jurisdictions.

Intercompany financing

• Conduct arm's length analyses for intercompany loans using interest-rate benchmarking, the CUP method or yield-curve approaches, credit-rating analysis, and thin-capitalisation analysis.
• Assess loan-to-value and debt-service coverage and advise on new financing structures.
• Monitor benchmark interest-rate changes and update intercompany loan pricing.

Compliance and cross-border support

• Maintain knowledge of Federal Decree-Law No. 47 of 2022, Ministerial Decision No. 97 of 2023, FTA kinship guidance, and Country-by-Country Reporting obligations.
• Support UAE Corporate Tax returns with accurate related-party disclosures and engage advisers on private clarification requests.
• Advise on cross-border transactions, withholding tax, restructurings, entity migrations, new jurisdictions, and Pillar Two profit allocation.
• Manage transfer pricing audits and authority enquiries and prepare technical position papers and responses.

Advisory and leadership

• Act as the primary transfer pricing adviser to the Real Estate business line during commercial structuring discussions.
• Brief tax leadership on material developments, risks, regulatory changes, and required provisions.
• Train and develop the India SSC transfer pricing analyst and collaborate on group-wide methodology and consistency.

Essential qualifications and experience

• ACA, CTA, ADIT, CPA, or an equivalent professional qualification with transfer pricing as a primary specialism.
• At least 8 years of transfer pricing experience, including at least 3 years in-house or advising a real estate or property business.
• Strong knowledge of OECD transfer pricing guidance, the arm's length principle, comparability analysis, and the five OECD methods.
• Direct UAE transfer pricing experience under Federal Decree-Law No. 47 of 2022 and Ministerial Decision No. 97 of 2023.
• Experience with UAE Transfer Pricing Disclosure Forms, Local Files, intercompany financing analysis, Big Four advisers, and multi-jurisdictional groups.
• Strong understanding of UAE related-party definitions, including kinship and affinity-based relationships.

Desirable experience

• Real estate or property-sector transfer pricing experience, including property management, development management, and land or asset holding structures.
• Familiarity with UAE FTA audits, private clarification requests, Country-by-Country Reporting, Pillar Two, or multi-tier UAE real estate holding structures.
• Arabic language skills are advantageous but not required.

Personal attributes