The Guide describes the Emirati understanding of the Arm’s Length Principle and the structure of TP documentation. In addition, 25 examples are given in which transfer pricing rules are applied. Examples include related party transactions, financial services (hedging, treasury functions, capturing insurance, cash pooling), intragroup services, intangible asset transactions, business restructurings, Cost Contribution Arrangements (CCAs), PE transactions, Cash/bank settlement.
Hyde should become the main source of recommendations on shopping centers. If some aspects are not covered by Hyde, companies are recommended to refer to the OECD Transfer Pricing Guidelines.