Related-party and connected-person rules are designed to prevent taxable income from being shifted through non-commercial pricing. For SMEs, the topic often appears through owner salaries, group recharges, loans, and family-owned company transactions.
Common SME Transactions
- Salary or bonus paid to an owner-manager
- Management fees between group companies
- Shared office or staff recharges
- Loans between related companies
- Rent paid to a related person
- Purchases or sales between family-owned entities
What Arm's Length Means
Arm's length means the transaction should be priced as if independent parties had agreed it under comparable commercial conditions. The records should explain the business reason and the pricing basis.
Practical Records
- Keep contracts or board approvals
- Document the service or asset provided
- Compare the price to market evidence where possible
- Post transactions consistently in the accounts
- Review material connected payments before filing
A payment to an owner is not automatically wrong. The risk is unsupported or excessive payment with no clear business basis.
What This Looks Like in Practice
Owner-managed SMEs often have connected payments even when they do not think of themselves as a group. Salary, rent, loans, recharges, and family-company dealings all need commercial support.
Records to Keep Before You Decide or File
- Financial statements, trial balance, and general ledger for the tax period
- Tax adjustment schedule showing deductible and non-deductible items
- Related-party, owner-payment, loan, and transfer-pricing support
- EmaraTax registration, filing, relief, and payment confirmations
Review Questions for the Owner
- Is the accounting profit reliable enough to be the starting point for tax?
- Have reliefs, exemptions, and free zone positions been documented instead of assumed?
- Are owner and related-party payments supported at arm's length?
- Can the business explain each material tax adjustment in plain English?
Mistakes That Make This Expensive
- Preparing the Corporate Tax return from unreconciled bookkeeping
- Treating owner drawings, dividends, and salary as the same thing
- Assuming no tax payable means no registration, filing, or records obligation
Practical Next Step
List connected transactions before year end and document the business reason, price basis, approval, and accounting treatment for each material item.
Keep a short working paper with the facts, dates, assumptions, and documents used. It makes future filing, review, or handover much easier.