Transaction & risk mapping
We identify every related party and connected person, list the controlled transactions between them, and flag where the pricing risk actually sits.
International & Regulatory Tax
UAE Transfer Pricing & benchmarking services
Under UAE Corporate Tax, every deal you do with a related party or connected person has to be priced as if it were a stranger — at arm's length — and you have to prove it. That means functional analysis, a benchmarking study, a disclosure form with your return, and Local and Master Files once you cross the thresholds. We build the documentation the FTA will accept and stand behind it if they ask — at a fixed fee agreed before we start.
Arm's length
The standard every related-party deal must meet
AED 200M
Revenue that triggers Local & Master File
AED 3.15bn
Group revenue that triggers CbCR
Fixed fee
Agreed before we start
What it means
What is Transfer Pricing?
Transfer Pricing is the set of rules that governs the price of any transaction between related parties and connected persons — group companies, owners, directors and the people close to them. The principle is simple to state and hard to prove: the price must be the one independent parties would have agreed in the same circumstances. That is the arm's length standard, and since UAE Corporate Tax began it applies to almost every group in the country.
It reaches further than most owners expect. A management fee from the holding company, a loan from a shareholder, a royalty for a brand, goods moved between a mainland trading arm and a free-zone entity, a director's remuneration — all of it has to be priced at arm's length, and payments to connected persons are only deductible to the extent they match market value and a genuine business service.
Proving arm's length means a benchmarking study: choosing the right OECD method, running a search for comparable independent companies, and landing your pricing inside a defensible arm's length range. The documentation then comes in tiers — a disclosure form filed with the Corporate Tax return, a Local File and Master File once you cross the revenue thresholds, and Country-by-Country Reporting for the largest multinational groups.
Get it right and related-party pricing is settled, deductible and audit-ready. Get it wrong and the FTA can re-price your transactions, disallow the deductions and apply penalties — often years after the fact. We build the analysis and the file so the position holds.
What we handle
What our Transfer Pricing service covers
One team takes you from a map of your related-party dealings to a filed, benchmarked, defensible file — and stands behind the positions in it if the FTA ever asks.
Benchmarking studies
Comparable-company searches in recognised databases, comparability adjustments and a documented arm's length range for each tested transaction.
Method selection & analysis
The right OECD method for each dealing — CUP, resale-price, cost-plus, TNMM or profit split — grounded in a proper functional and comparability analysis.
Local File & Master File
Full contemporaneous documentation to the OECD structure — the entity-level Local File and the group-wide Master File — where the thresholds apply.
Disclosure form & CbCR
The Transfer Pricing disclosure form filed with your Corporate Tax return, and Country-by-Country Reporting notification and filing for large groups.
Policy, agreements & FTA defence
A written TP policy and intercompany agreements that match reality — plus responses to FTA queries, audits and any proposed adjustments.
What's involved
What Transfer Pricing compliance needs
A defensible file is built long before the return is due. These are the essentials we put in place and keep current through the year.
A related-party register
A complete list of related parties and connected persons, and the controlled transactions with each — the foundation everything else rests on.
Intercompany agreements
Written agreements for loans, services, royalties and cost sharing — priced and worded to match what actually happens between the entities.
A functional analysis
Who does what, who owns which assets and who bears which risks across the group — the basis for choosing a method and its comparables.
A defensible benchmarking study
A documented comparables search, adjustments and arm's length range for each tested transaction — refreshed on a sensible cycle.
The TP disclosure form
The disclosure schedule completed and filed with the Corporate Tax return whenever related-party transactions cross the reporting thresholds.
Local & Master File on time
Where revenue or group thresholds apply, both files prepared contemporaneously and ready to produce within the FTA's request window.
CbCR where required
For large multinational groups, the Country-by-Country notification and report filed correctly and on schedule.
Contemporaneous records
Documentation prepared in the period it relates to and retained — after-the-fact files carry far less weight in an FTA review.
The signals
When you need Transfer Pricing support
Transfer Pricing problems rarely announce themselves — they surface as a disallowed deduction, an FTA query or a threshold quietly crossed. If any of these apply, talk to us early.
You deal with group companies
Goods, services, loans or royalties move between your entities, or between the company and its owners — all of it needs arm's length pricing.
You're part of a multinational group
Cross-border charges bring Master File, CbCR and the scrutiny of more than one tax authority into play at once.
Your revenue is nearing a threshold
Approaching AED 200 million turns documentation from optional to mandatory — the file has to exist before the return is filed.
You charge fees across borders
Management fees, royalties and shared costs are the first things an auditor tests — and the easiest to have priced without support.
The FTA has queried your pricing
A question about related-party dealings or a proposed adjustment needs a documented, method-based response — quickly.
You're restructuring or moving IP
Shifting functions, assets or intellectual property between entities is exactly where transfer-pricing risk concentrates — plan it before you move.
How we help
From related-party map to defended file, in five clear steps
One team runs the full Transfer Pricing cycle — with a fixed fee agreed up front and a clear view of which step you're on.
1
Week 1
Map & scope
We identify your related parties and connected persons, list the controlled transactions, and size the documentation you actually need.
2
Week 2–4
Analyse & benchmark
We run the functional analysis, select the right method for each dealing, and build the benchmarking study and arm's length ranges.
3
Week 4–6
Document
We prepare the Local File, Master File and intercompany agreements, and set out a written TP policy that matches how the group operates.
4
At filing
Disclose & file
We complete the disclosure form with the Corporate Tax return and handle CbCR notification and filing where the group thresholds apply.
5
Ongoing
Defend & maintain
We refresh benchmarks, answer FTA queries, and defend the pricing through any audit or proposed adjustment as the group evolves.
Get started
Get your related-party pricing on solid ground.
Tell us about your group — the entities, where they sit and the dealings between them — and we'll reply within one business day with a clear view of what you need and an all-inclusive price.
Thank you — we've got your details.
One of our Transfer Pricing advisors will be in touch within one business day.
One of our Transfer Pricing advisors will be in touch within one business day.