Senior Manager

About DAMAC Group

Role Purp

Key Responsibil

• ities1.
• UAE Transfer Pricing — Real Estate Business
• LineOwn the transfer pricing framework for all intercompany transactions within the Real Estate business line, inclu
• ding:Intercompany property management fees between UAE ent
• itiesIntercompany financing arrangements and shareholder
• loansCorporate services and overhead recharge agree
• mentsConstruction and development management
• feesSales and marketing services agreements between group ent
• itiesEnsure all intercompany transactions are priced on an arm's length basis in accordance with the UAE CT Law and OECD Transfer Pricing Guide
• linesDraft, review, and maintain intercompany agreements for all in-scope Properties transac
• tionsManage the annual UAE related-party disclosure process for Properties entities, including completion of the Transfer Pricing Disclosure
• FormMaintain awareness of UAE Federal Tax Authority guidance on related-party definitions, including kinship-based relationships under the UAE CT Law, and advise the business accord
• ingly

2. TP Documentation — UAE & Interna

• tionalPrepare and maintain Local File documentation for the Properties business line across all relevant jurisdi
• ctionsCoordinate with the SM — Transfer Pricing (Data Centre) on the group Master File to ensure consistent group-level TP nar
• rativeManage the external Big 4 relationship for Properties TP benchmarking studies — briefing, reviewing, and challenging o
• utputsEnsure TP documentation is updated annually and is audit-ready at all
• timesOversee the India SSC TP Analyst's preparation of working papers, intercompany transaction data, and entity-level P&L analysis feeding into the documen
• tationMonitor TP documentation thresholds across jurisdictions and ensure filing deadlines a
• re met

3. Intercompany Financing — Arm's Length A

• nalysisConduct and maintain arm's length analyses for all intercompany loan arrangements within the Properties business, inc
• luding:Interest rate benchmarking using the comparable uncontrolled price (CUP) method or yield curve app
• roachesCredit rating analysis for borrowing e
• ntitiesThin capitalisation analysis under UAE and applicable foreign jurisdictio
• n rulesLoan-to-value and debt service coverage ass
• essmentAdvise on the structuring of new intercompany financing arrangements to ensure arm's length compliance from in
• ceptionMonitor changes to benchmark interest rates and update intercompany loan pricing acco
• rdingly
• 4.
• UAE Transfer Pricing — Regulatory & Co
• mplianceMaintain a current and detailed understanding of the UAE transfer pricing framework, in
• cluding:Federal Decree-Law No. 47 of 2022 (Corporate Tax Law) — Articles 34–36 on related parties and connected
• personsMinisterial Decision No. 97 of 2023 — TP rules, documentation requirements, and disclosure obl
• igationsFTA guidance on kinship-based related party definitions — degrees of kinship and affinity, including in-law relat
• ionshipsCountry-by-Country Reporting obligations (CbCR) for t
• he groupMonitor and assess the impact of evolving UAE FTA guidance on the group's TP positions and disclosure obl
• igationsEngage with external UAE tax advisers on FTA private clarification requests where the related-party definition or arm's length position requires FTA conf
• irmationSupport UAE CT return preparation with accurate related-party transaction dis
• closures

5. Cross-Border Transfer Pricin

• g SupportProvide TP support for cross-border related-party transactions involving the Properties business line, including transactions with group entities in the UK, US, and other juri
• sdictionsAdvise on withholding tax implications of intercompany service fees and financing flows in the context of the arm's length
• standardSupport the Director — CT UAE Properties on TP aspects of corporate restructurings, entity migrations, and new jurisdictio
• n entriesContribute to the group's Pillar Two (OECD Global Minimum Tax) analysis as it relates to TP-driven profit allocation across juri
• sdictions

6. Audit Defence & C

• ontroversyManage TP audit enquiries from the UAE FTA and tax authorities in other jurisdictions, working with external advisers wher
• e requiredPrepare TP position papers and technical responses to authori
• ty queriesAdvise the Senior Director — Direct Tax and Group Head of Tax on material TP risks and provision
• s requiredMonitor TP audit trends in the UAE and across the group's jurisdictions and provide proactive risk
• assessment

7. Internal Advisory & Stakeholder

• ManagementAct as the primary TP adviser to the Real Estate business line — attending key commercial discussions where intercompany structuring implica
• tions ariseBrief the Senior Director — Direct Tax and Group Head of Tax on material TP developments, risks, and regulat
• ory changesTrain and develop the India SSC TP Analyst, building internal capability in TP data preparation and working paper
• productionCollaborate with the SM — Transfer Pricing (Data Centre) on group-wide TP consistency, Master File narrative, and shared methodolog
• y questions

&

• ; Experie
• nceEssentialProfessional qualification: ACA, CTA, ADIT, CPA, or equivalent — with transfer pricing as a primar
• y specialismMinimum 10 years of transfer pricing experience, with at least 3 years in an in-house role or advising a real estate / prope
• rty businessStrong technical knowledge of the OECD Transfer Pricing Guidelines, including the arm's length principle, comparability analysis, and the five OEC
• D TP methodsDirect experience with UAE transfer pricing rules under Federal Decree-Law No. 47 of 2022 and Ministerial Decision No
• . 97 of 2023Experience preparing or reviewing UAE Transfer Pricing Disclosure Forms and Local File d
• ocumentationHands-on experience with intercompany financing TP — interest rate benchmarking, credit rating analysis, and thin ca
• pitalisationExperience managing and briefing external Big 4 or specialist TP advisers, including reviewing and challenging benchmar
• king studiesStrong understanding of related-party definitions under UAE law, including kinship and affinity-based r
• elationshipsExperience operating in a multi-jurisdictional group with complex intercompany trans
• action flows

Hig

• hly DesirableExperience with real estate or property sector transfer pricing — including property management fees, development management fees, and land/asset holdi
• ng structuresFamiliarity with UAE FTA audit processes and private clarification reque
• st proceduresExperience with Country-by-Country Reporting preparati
• on and filingKnowledge of Pillar Two (OECD Global Minimum Tax) as it affects TP-driven prof
• it allocationExposure to intercompany TP in the context of a US-listed or listing-stage
• multinationalArabic language skills — an advantage in FTA interactions but
• not requiredExperience with TP aspects of real estate holding structures involving multiple tiers of
• UAE entities

Perso

• nal AttributesDetail-oriented — TP documentation quality is a direct audit defence tool; precision is
• non-negotiableCommercially aware — understands the business drivers behind intercompany transactions and structures pricing to reflect ec
• onomic realityProactive — identifies TP risks before they crystallise and brings solutions, n
• ot just issuesClear communicator — able to explain complex TP concepts to non-tax finance and busin
• ess colleaguesCollaborative — works effectively across the tax function (with CIT colleagues, the SSC, and the Data Centre TP SM) and externally with
• Big 4 advisersOrganised — manages multiple documentation cycles, jurisdictions, and deadlines simultaneously without
• losing qualityAdaptable — comfortable working in a jurisdiction (UAE) where regulatory guidance is still developing and where professional judgement is frequ
• ently required