About DAMAC Group
DAMAC Group is a global real estate and AI infrastructure business headquartered in Dubai, UAE. The group operates across the UAE, United States, United Kingdom, Malaysia, Thailand, and Indonesia, with significant and expanding operations in both the residential and commercial real estate sector and in AI infrastructure and data centre development.
The Tax & Corporate Structuring function is led by the Group Head of Tax & Corporate Structuring and covers indirect tax, direct tax, and transfer pricing across all jurisdictions. The function is structured across three pillars, with a Dubai-based senior team supported by a growing India Shared Services Centre and external Big 4 advisers retained on a specialist mandate
This role sits within the Transfer Pricing pillar and is a new hire, created to provide dedicated senior manager-level TP coverage for the group's Real Estate business line and to strengthen the overall transfer pricing function as the group's international footprint expand
Role Purpose
The Senior Manager — Transfer Pricing (Properties) will own the end-to-end transfer pricing framework for the group's Real Estate business line, covering intercompany transactions across the UAE and all jurisdictions where the Properties business has related-party dealings. The role will also provide broader TP support across the group where workloads require it
A key feature of this role is the application of UAE transfer pricing rules under Federal Decree-Law No. 47 of 2022 and Ministerial Decision No. 97 of 2023, including the group's obligations around related-party disclosure, the arm's length principle, and the specific UAE rules on kinship-based related party definitions. The role owner must be comfortable operating in a jurisdiction where TP guidance continues to evolve and where the FTA's interpretation of related party definitions — including in-law and extended family relationships — requires ongoing monitoring.
The SM — Transfer Pricing (Properties) reports to the Senior Director — Direct Tax and works closely with the SM — Transfer Pricing (Data Centre), the Director — CT UAE Properties, and the India SSC TP Analyst
Key Responsibilities
1. UAE Transfer Pricing — Real Estate Business Line
- Own the transfer pricing framework for all intercompany transactions within the Real Estate business line, including
-Intercompany property management fees between UAE entities
-Intercompany financing arrangements and shareholder loans
-Corporate services and overhead recharge agreements
-Construction and development management fees
-Sales and marketing services agreements between group entities
- Ensure all intercompany transactions are priced on an arm's length basis in accordance with the UAE CT Law and OECD Transfer Pricing Guidelines
- Draft, review, and maintain intercompany agreements for all in-scope Properties transactions
- Manage the annual UAE related-party disclosure process for Properties entities, including completion of the Transfer Pricing Disclosure Form
- Maintain awareness of UAE Federal Tax Authority guidance on related-party definitions, including kinship-based relationships under the UAE CT Law, and advise the business accordingly
2. TP Documentation — UAE & International
- Prepare and maintain Local File documentation for the Properties business line across all relevant jurisdictions
- Coordinate with the SM — Transfer Pricing (Data Centre) on the group Master File to ensure consistent group-level TP narrative
- Manage the external Big 4 relationship for Properties TP benchmarking studies — briefing, reviewing, and challenging outputs
- Ensure TP documentation is updated annually and is audit-ready at all times
- Oversee the India SSC TP Analyst's preparation of working papers, intercompany transaction data, and entity-level P&L analysis feeding into the documentation
- Monitor TP documentation thresholds across jurisdictions and ensure filing deadlines are met
3. Intercompany Financing — Arm's Length Analysis
- Conduct and maintain arm's length analyses for all intercompany loan arrangements within the Properties business, including:
- Interest rate benchmarking using the comparable uncontrolled price (CUP) method or yield curve approaches
- Credit rating analysis for borrowing entities
- Thin capitalisation analysis under UAE and applicable foreign jurisdiction rules
- Loan-to-value and debt service coverage assessment
- Advise on the structuring of new intercompany financing arrangements to ensure arm's length compliance from inception
- Monitor changes to benchmark interest rates and update intercompany loan pricing accordingly
4. UAE Transfer Pricing — Regulatory & Compliance
- Maintain a current and detailed understanding of the UAE transfer pricing framework, including:
- Federal Decree-Law No. 47 of 2022 (Corporate Tax Law) — Articles 34–36 on related parties and connected persons
- Ministerial Decision No. 97 of 2023 — TP rules, documentation requirements, and disclosure obligations
- FTA guidance on kinship-based related party definitions — degrees of kinship and affinity, including in-law relationships
- Country-by-Country Reporting obligations (CbCR) for the group
- Monitor and assess the impact of evolving UAE FTA guidance on the group's TP positions and disclosure obligations
- Engage with external UAE tax advisers on FTA private clarification requests where the related-party definition or arm's length position requires FTA confirmation
- Support UAE CT return preparation with accurate related-party transaction disclosures
5. Cross-Border Transfer Pricing Support
- Provide TP support for cross-border related-party transactions involving the Properties business line, including transactions with group entities in the UK, US, and other jurisdictions
- Advise on withholding tax implications of intercompany service fees and financing flows in the context of the arm's length standard
- Support the Director — CT UAE Properties on TP aspects of corporate restructurings, entity migrations, and new jurisdiction entries
- Contribute to the group's Pillar Two (OECD Global Minimum Tax) analysis as it relates to TP-driven profit allocation across jurisdictions
6. Audit Defence & Controversy
- Manage TP audit enquiries from the UAE FTA and tax authorities in other jurisdictions, working with external advisers where required
- Prepare TP position papers and technical responses to authority queries
- Advise the Senior Director — Direct Tax and Group Head of Tax on material TP risks and provisions required
- Monitor TP audit trends in the UAE and across the group's jurisdictions and provide proactive risk assessment
7. Internal Advisory & Stakeholder Management
- Act as the primary TP adviser to the Real Estate business line — attending key commercial discussions where intercompany structuring implications arise
- Brief the Senior Director — Direct Tax and Group Head of Tax on material TP developments, risks, and regulatory changes
- Train and develop the India SSC TP Analyst, building internal capability in TP data preparation and working paper production
- Collaborate with the SM — Transfer Pricing (Data Centre) on group-wide TP consistency, Master File narrative, and shared methodology questions
Qualifications & Experience
Essential
- Professional qualification: ACA, CTA, ADIT, CPA, or equivalent — with transfer pricing as a primary specialism
- Minimum 8 years of transfer pricing experience, with at least 3 years in an in-house role or advising a real estate / property business
- Strong technical knowledge of the OECD Transfer Pricing Guidelines, including the arm's length principle, comparability analysis, and the five OECD TP methods
- Direct experience with UAE transfer pricing rules under Federal Decree-Law No. 47 of 2022 and Ministerial Decision No. 97 of 2023
- Experience preparing or reviewing UAE Transfer Pricing Disclosure Forms and Local File documentation
- Hands-on experience with intercompany financing TP — interest rate benchmarking, credit rating analysis, and thin capitalisation
- Experience managing and briefing external Big 4 or specialist TP advisers, including reviewing and challenging benchmarking studies
- Strong understanding of related-party definitions under UAE law, including kinship and affinity-based relationships
- Experience operating in a multi-jurisdictional group with complex intercompany transaction flows
Highly Desirable
- Experience with real estate or property sector transfer pricing — including property management fees, development management fees, and land/asset holding structures
- Familiarity with UAE FTA audit processes and private clarification request procedures
- Experience with Country-by-Country Reporting preparation and filing
- Knowledge of Pillar Two (OECD Global Minimum Tax) as it affects TP-driven profit allocation
- Exposure to intercompany TP in the context of a US-listed or listing-stage multinational
- Arabic language skills — an advantage in FTA interactions but not required
- Experience with TP aspects of real estate holding structures involving multiple tiers of UAE entities
Personal Attributes
- Detail-oriented — TP documentation quality is a direct audit defence tool; precision is non-negotiable
- Commercially aware — understands the business drivers behind intercompany transactions and structures pricing to reflect economic reality
- Proactive — identifies TP risks before they crystallise and brings solutions, not just issues
- Clear communicator — able to explain complex TP concepts to non-tax finance and business colleagues
- Collaborative — works effectively across the tax function (with CIT colleagues, the SSC, and the Data Centre TP SM) and externally with Big 4 advisers
- Organised — manages multiple documentation cycles, jurisdictions, and deadlines simultaneously without losing quality
- Adaptable — comfortable working in a jurisdiction (UAE) where regulatory guidance is still developing and where professional judgement is frequently required
